Facts
- Minnesota police suspected Robert M. Olson of serving as the getaway driver in a robbery-murder.
- Officers believed Olson was staying overnight at the home of two women.
- After recovering the murder weapon and arresting the suspected gunman, police surrounded the home and telephoned, asking Olson to come out; a male voice said, “tell them I left.”
- Without consent and with weapons drawn, officers entered the home, found Olson hiding in a closet, and arrested him.
- Olson later made an inculpatory statement.
- The trial court denied suppression and Olson was convicted of murder, armed robbery, and assault.
Issues
- Whether an overnight guest has a legitimate expectation of privacy in the host’s home sufficient to challenge a warrantless entry and arrest under the Fourth Amendment.
- Whether exigent circumstances justified the warrantless entry into the home to arrest Olson.
Decision
- The Supreme Court affirmed the Minnesota Supreme Court in a 7–2 decision.
- The Court held that Olson’s status as an overnight guest, standing alone, established a reasonable expectation of privacy in the home.
- The Court held that the warrantless entry and arrest violated the Fourth Amendment because the circumstances were not exigent.
- The Court agreed that Olson’s post-arrest inculpatory statement was tainted by the illegal entry and arrest and was subject to suppression.
Legal Principles
- An overnight guest has a Fourth Amendment-protected reasonable expectation of privacy in the host’s home, even without a property interest or authority to admit or exclude others.
- Formal property-based distinctions (e.g., having a key or control of access) are not determinative of Fourth Amendment standing for an overnight guest.
- Warrantless home entries to arrest are presumptively unreasonable and require clearly established exigent circumstances.
- Exigency may include hot pursuit, imminent destruction of evidence, prevention of escape, or danger to police or others; absent hot pursuit, police must have probable cause to believe such conditions exist, with danger assessed in light of crime gravity and likelihood the suspect is armed.
- Where police have secured the scene, recovered key evidence, and the suspect has no realistic avenue of escape, generalized concerns about serious crime or flight do not establish exigency.
Conclusion
The Court ruled that an overnight guest may challenge a warrantless entry into the host’s home and that, on the facts presented, police lacked exigent circumstances to enter without a warrant, requiring suppression of the resulting statement.