## Facts

- Police conducted a “hotel interdiction” at a Bloomington, Minnesota hotel without responding to a specific call or tip.
- Without a warrant and without individualized suspicion, officers requested to examine the hotel guest registry and asked for names of guests who paid in cash.
- Minnesota statutes required hotels to maintain registries with guest identifying information and to make them available to law enforcement; noncompliance carried penalties.
- A clerk identified John Thomas Leonard as a cash-paying guest; officers used the registry to determine his room and then ran a background check that increased their suspicion.
- Officers went to Leonard’s room without a warrant; after Leonard attempted to flee, they detained him.
- Officers later obtained a warrant to search the room and discovered suspected forged checks that formed the basis for a check-forgery charge.
- Leonard moved to suppress the evidence, arguing the registry inspection was an unreasonable search under the Minnesota Constitution and the later evidence was derivative.

## Issues

1. Whether law enforcement examination of a hotel guest registry is a “search” under Article I, § 10 of the Minnesota Constitution.
2. If it is a search, whether police must have at least reasonable, articulable suspicion to inspect the registry, or whether the hotel-registry statutes permit suspicionless access.
3. Whether evidence obtained from the hotel room after the registry inspection must be suppressed as fruit of an unconstitutional search.

## Decision

- The Minnesota Supreme Court held that police examination of a hotel guest registry is a search under Article I, § 10 of the Minnesota Constitution.
- The court held that officers must have at least reasonable, articulable suspicion to inspect a guest registry; suspicionless registry inspections are unconstitutional.
- The court held the hotel guest registry statutes were constitutional because their “open” and “accessible” language does not authorize suspicionless searches.
- The court ruled the district court erred by admitting evidence from the hotel room as fruit of the unlawful registry search.
- The court reversed the court of appeals and remanded for further proceedings.

## Legal Principles

- Under the Minnesota Constitution, government inspection of hotel guest registry information constitutes a search because it reveals sensitive information about an individual’s location and associations.
- Suspicionless “interdiction” review of a hotel registry is unreasonable; police must have reasonable, articulable suspicion before inspecting the registry.
- Statutory requirements that hotels keep registries available to law enforcement do not eliminate constitutional limits on police access; statutes are construed to operate within Article I, § 10.
- Evidence obtained by exploiting information learned from an unconstitutional registry search is subject to suppression as fruit of the poisonous tree, including evidence seized later pursuant to a warrant derived from the unlawful access.

## Conclusion

The court required reasonable, articulable suspicion for police inspection of hotel guest registries under the Minnesota Constitution and ordered suppression of evidence obtained through a warrant that flowed from a suspicionless registry search.


State v. Leonard, 943 N.W.2d 149 (Minn. 2020)