Minnesota v. Olson

While the defendant in this case was not the legal owner of the home, he was an “overnight guest” there. This fact allowed him to create a reasonable expectation of privacy in the home. An overnight guest “seeks shelter in another’s home precisely because it provides him with privacy, a place where he and his possessions will not be disturbed by anyone but his host and those his host allows inside.”

No exigent circumstances existed that would excuse the officers’ warrantless entry into the home. While the crime was serious, the defendant was not considered to be the murderer, but only the getaway driver. The officers had previously recovered the murder weapon and there was no evidence that the two women inside the residence were in danger. The officers had the home surrounded. It was apparent that the defendant was not able to leave. If he had, he would have been arrested in a public place. For all of these reasons, exigent circumstances did not exist to enter the home. The defendant’s statement was suppressed as the fruit of his unlawful arrest.