Facts
- A police officer investigated a tip that people were placing white powder into bags in a ground-floor apartment.
- From outside the apartment, the officer looked through a gap in a closed window blind and observed Carter, Johns, and the lessee bagging cocaine.
- Police later stopped a vehicle leaving the area with Carter and Johns inside and recovered cocaine and drug-related items.
- Police arrested the apartment lessee and, pursuant to a warrant, recovered cocaine residue and packaging materials from the apartment.
- Carter and Johns were from out of state, had no prior connection to the apartment or lessee, and had been in the apartment for about 2.5 hours solely to package cocaine in exchange for payment in drugs.
- Carter and Johns moved to suppress evidence, arguing the initial window observation was an unconstitutional search.
Issues
- Whether short-term visitors present in another’s apartment for a commercial drug-packaging operation had a reasonable expectation of privacy protected by the Fourth Amendment.
- Whether, if the officer’s window observation was a “search,” it violated the defendants’ personal Fourth Amendment rights such that suppression was required.
Decision
- The Supreme Court reversed the state supreme court and remanded.
- The Court held Carter and Johns lacked a legitimate expectation of privacy in the apartment under the circumstances.
- Even assuming the officer’s conduct constituted a search, it did not violate respondents’ Fourth Amendment rights, so suppression was unavailable on their motion.
Legal Principles
- Fourth Amendment protections are personal; a defendant must show a personal, reasonable expectation of privacy in the place searched.
- “Standing” labels do not control; the inquiry is whether the defendant’s own Fourth Amendment rights were infringed.
- Overnight social guests generally have a reasonable expectation of privacy in a host’s home, but mere presence with the householder’s consent may not.
- A short, purely commercial presence in another’s home—especially with no prior relationship to the householder—strongly negates a reasonable expectation of privacy.
Conclusion
Because respondents were brief, commercial visitors with no prior connection to the apartment or its lessee, they had no reasonable expectation of privacy in the premises; therefore, the officer’s observation did not violate their Fourth Amendment rights, and the evidence was not suppressible on their motion.