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Minnesota v. Olson

    Brief Fact Summary. Police entered a home where plaintiff was an overnight guest without a warrant.

    Synopsis of Rule of Law. “[S]tatus as an overnight guest is alone enough to show that [an individual] had an expectation of privacy in the home that society is prepared to recognize as reasonable.”

    Facts. A gas station was robbed and the station manager was fatally shot. A police officer heard a police dispatcher report and suspected an individual named Joseph Ecker (“Mr. Ecker”). The officer who heard the report and his partner went to Mr. Ecker’s home. The police arrived at Mr. Ecker’s home at the same time an Oldsmobile arrived. The driver of the Oldsmobile took evasive action and spun out of control and then came to a stop. The two occupants of the vehicle fled on foot. Mr. Ecker was captured inside his home, but the second man escaped. The police found a sack of money and the murder weapon in the car. Also, a title certificate with the Respondent’s name, Robert Olson (the “Respondent”), on it. The next day, the police received a telephone call from an individual informing them that someone named Rob drove the getaway car and was about to leave town by bus. The caller called back a second time and provided the police with an address, a duplex. The Respondent live
    d on the upper floor of the duplex. The police called the residence, but the Respondent was not home. The individual who called the police promised to call when the Respondent got home. The police received a call informing them the Respondent had returned and the police surrounded the home. The police “[w]ithout seeking permission and with weapons drawn, the police entered the upper unit and found respondent hiding in a closet. Less than an hour after his arrest, respondent made an inculpatory statement at police headquarters.”
    The state trial court held a suppression hearing and denied the Respondent’s motion to suppress his statement. The statement was admitted into evidence and the Respondent was convicted of various crimes. The Minnesota Supreme Court reversed. “The court ruled that respondent had a sufficient interest in the [ ] home to challenge the legality of his warrantless arrest there, that the arrest was illegal because there were no exigent circumstances to justify a warrantless entry, and that respondent’s statement was tainted by that illegality and should have been suppressed.”

    Issue. Whether “a warrantless, nonconsensual entry into a house where respondent


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