Minnesota v. Carter
Minnesota v. Carter is a significant Supreme Court case that addresses the issue of privacy expectations for individuals in a home, particularly concerning guests in a commercial context. The case arose when police officers, acting on a tip, observed men in a ground floor apartment apparently engaging in illegal drug activity. Upon the arrest of two guests as they left the apartment, their defense argued that the police observation constituted an unreasonable search, violating the Fourth Amendment rights.
The Supreme Court's ruling, delivered by Chief Justice William H. Rehnquist, highlighted the transient nature of the guests' visit and their lack of a pre-existing relationship with the apartment's resident. The Court concluded that, due to the primarily commercial purpose of their stay and the short duration, the guests did not have a legitimate expectation of privacy typically afforded to individuals in a home setting. This decision was nuanced by a concurring opinion from Justice Anthony M. Kennedy, who suggested that most social guests would usually expect privacy in a host's home. Thus, the case plays a crucial role in delineating the boundaries of privacy rights in different contexts, emphasizing how the nature of the visit can influence legal expectations.
Minnesota v. Carter
Date: December 1, 1998
Citation: No. 97-1147
Issue: Right to privacy
Significance: The Supreme Court held that guests in a private home had no expectation of privacy if they had no personal relationship with the householder and were in the home for a few hours purely to conduct a business transaction.
Responding to a tip, a Minnesota police officer looked through a gap in a closed blind located in a ground floor apartment and observed three men bagging white powder that looked like cocaine. The two guests were arrested after they left the apartment. At trial, their lawyers moved to suppress the evidence on the grounds that the initial observation was an unreasonable search that violated the Fourth Amendment. They referred to Minnesota v. Olson (1990), in which the Supreme Court held that an overnight guest had a legitimate expectation of privacy within the home visited. In other cases, in contrast, the Court had held that the expectation of privacy in commercial property was less than in a private home.
Writing for a 6-3 majority, Chief Justice William H. Rehnquist emphasized the commercial purpose of the visit, the relatively short time the visitors were in the building, and the lack of any previous connection between them and the householder. Because the visitors had no legitimate expectation of privacy in the home, the Court did not make a decision about whether the officer’s observation constituted a search. Justice Anthony M. Kennedy spoke for at least five justices in his concurring opinion, noting that “almost all social guests” would have a legitimate expectation of privacy in a host’s home.