Minnesota v. Carter Case Brief

Why is the case important?

“Wayne Thomas Carter, Melvin Johns and Kimberly Thompson were arrested after a police officer observed them through a window bagging cocaine. Carter and Johns moved to suppress the evidence, under the theory that they had Fourth Amendment protection against unreasonable search and seizure

  • however, the court held this does not apply to individuals who merely visit another’s home.”

    Facts of the case

    Wayne Thomas Carter, Melvin Johns, and Kimberly Thompson were arrested after a police officer observed them through a window bagging cocaine in Thompson’s apartment. During the trial in Minnesota state court, the defendants moved to suppress the cocaine as evidence. They argued the officer’s initial observation was an unreasonable search and seizure in violation of their Fourth Amendment rights. Subsequently, they were all convicted on state drug charges. The Minnesota trial court held that because they were not overnight social guests they were not protected by the Fourth Amendment. Moreover, the court held that the officer’s window-based observation was not a search under the Fourth Amendment. On appeal, the state intermediate appellate court held Carter did not have standing for an objection to the officer’s action because his use of the apartment for drug purposes removed any legitimate expectation of privacy. The court also affirmed Johns’ conviction . The Minnesota Supreme Court reversed. It held that the defendants had a legitimate expectation of privacy in the invaded place and that the officer’s observation constituted an unreasonable search. Minnesota sought a writ of certiorari in the U.S. Supreme Court.

    Question

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    Answer

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    Conclusion

    “Any search that may have occurred did not violate respondents’ Fourth Amendment rights. The state courts’ analysis of respondents’ expectation of privacy under the rubric of “”standing”” doctrine was expressly rejected in Rakas v. Illinois, 439 U.S. 128, 140, 58 L. Ed. 2d 387, 99 S. Ct. 421 . Rather, to claim Fourth Amendment protection, a defendant must demonstrate that he personally has an expectation of privacy in the place searched, and that his expectation is reasonable. The Fourth Amendment protects persons against unreasonable searches of “”their persons [and] houses,”” and thus indicates that it is a personal right that must be invoked by an individual. But the extent to which the Amendment protects people may depend upon where those people are. While an overnight guest may have a legitimate expectation of privacy in someone else’s home, see Minnesota v. Olson, 495 U.S. 91, 98-99, 109 L. Ed. 2d 85, 110 S. Ct. 1684 , one who is merely present with the consent of the householder may not, see Jones v. United States, 362 U.S. 257, 259, 4 L. Ed. 2d 697, 80 S. Ct. 725 . And an expectation of privacy in commercial property is different from, and less than, a similar expectation in a home. New York v. Burger, 482 U.S. 691, 700, 96 L. Ed. 2d 601, 107 S. Ct. 2636 . Here, the purely commercial nature of the transaction, the relatively short period of time that respondents were on the premises, and the lack of any previous connection between them and the householder all lead to the conclusion that their situation is closer to that of one simply permitted on the premises. Any search which may have occurred did not violate their Fourth Amendment rights. Because respondents had no legitimate expectation of privacy, the Court need not decide whether the officer’s observation constituted a “”search.”””

    • Case Brief: 1998
    • Petitioner: Minnesota
    • Respondent: Carter
    • Decided by: Rehnquist Court

    Citation: 525 US 83 (1998)
    Argued: Oct 6, 1998
    Decided: Dec 1, 1998