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Minnesota v. Carter

Facts

The defendant and the lessee of an apartment packaged cocaine in the apartment. A law enforcement officer observed this activity by looking through a drawn window blind. The defendant did not live in the apartment, he had never visited that apartment before and his visit only lasted a matter of hours. His singular purpose in being there was to package cocaine. The defendant was arrested for conspiracy to commit a controlled substance crime. He complained that the information that led to his arrest was the product of an unreasonable search.

Issue

Whether a visitor enjoys a reasonable expectation of privacy in a premises visited for commercial reasons?

Held

No. Commercial visitors do not obtain a reasonable expectation of privacy in a premises.

Discussion

The Supreme Court distinguished the defendant’s presence in this apartment from the social, overnight guests’ presence in Minnesota v. Olson. In Olson, the Court held that a guest staying overnight in another’s home had a reasonable expectation of privacy. The defendant in Carter however, went to the apartment for a business transaction, limiting his presence to a matter of hours. He did not have a previous relationship with the lessee of the apartment, nor did he have a connection to the apartment similar to that of an overnight guest. While the apartment was a dwelling for the lessee, the property was equivalent to a commercial site to the defendant. Lacking a significant connection to the property, the defendant did not have standing to object to the search conducted on that premises.

Citation

525 U.S. 83, 119 S. Ct. 469 (1998)

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