Minnesota v. Olson

How later courts described this case

• finding exigent circumstances did not justify a warrantless entry into an upstairs duplex for the purpose of arresting an overnight guest believed to be involved in a murder where the police knew that the suspect was in the upstairs duplex with no suggestion of *369 danger to the other occupants of the duplex, the police had already recovered the murder weapon, the police thought the suspect was the driver of the getaway car and knew he was not the murderer, the police had surrounded the duplex, it was evident that the suspect was going nowhere, and the suspect would have been promptly apprehended had he exited the duplex
• holding that an overnight guest possessed 1Officers testified that they removed the car from the scene because onlookers were becoming argumentative and combative; the officers feared for their safety as well as for the integrity of the crime scene. Our review of the surveillance CD shows a couple of curious passersby. -3- a legitimate expectation of privacy and was thus entitled to the protection of the Fourth Amendment
• explaining that “a person may have a sufficient interest in a place other than his home to enable him to be free in that place from unreasonable searches and seizures,” and more specifically that “a houseguest has a legitimate expectation of privacy in his host’s home”
• finding that a defendant’s status as an overnight guest in the upper unit of a duplex home was sufficient for him to claim a protected privacy interest in the premises, even though he was not given a key or left alone in the unit, and did not pay for his stay

Written by the judges who cited it.