Minnesota v. Olson

In Minnesota v. Olson, 495 U.S. 91 (1990), the Court held that an overnight guest in the house of another carried an expectation of privacy that is protected by the Fourth Amendment. The Court concluded that an overnight guest stays in another's home because it provides privacy and security, where the guest and his possessions will not be disturbed by anyone except those the host allows inside. The Supreme Court held that "status as an overnight guest is alone enough to show that a person had a reasonable expectation of privacy in the home that society is prepared to recognize as reasonable." (At pp. 96-97.) In reaching this conclusion, the court reasoned, "From the overnight guest's perspective, he 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. We are at our most vulnerable when we are asleep . . . . It is for this reason that . . . when we cannot sleep in our own home we seek out another private place to sleep, whether it be a hotel room, or the home of a friend. Society expects at least as much privacy in these places as in a telephone booth--'a temporary private place whose momentary occupants' expectations of freedom from intrusion are recognized as reasonable.' " ( Id. at p. 99.) The Court further noted that people are most vulnerable when they are asleep because they cannot monitor their own safety nor the security of their belongings. For those reasons, the Court indicated, people seek another private place to sleep when they cannot sleep in their own homes. The Court held that an overnight guest had a reasonable expectation of privacy, so that a warrantless entry into the house to arrest him violated his Fourth Amendment right to freedom from an unreasonable search and seizure. The Court commented that its holding "merely recognizes the everyday expectations of privacy that we all share. Staying overnight in another's home is a longstanding social custom that serves functions recognized as valuable by society." 495 U.S. at 98.