Randy Michael Williams v. State of Florida

Summary

The First District Court of Appeal affirmed Randy Michael Williams's convictions and sentences after concluding that hotel staff lawfully ejected him under section 509.141, Florida Statutes. The court held that Williams no longer had a protected privacy interest in his hotel room when deputies searched it after hotel staff invited them inside. The court alternatively held that the good-faith exception to the exclusionary rule applied.

Holdings

1. The hotel lawfully ejected Williams because competent, substantial evidence established statutory grounds for removal, including conduct disturbing the peace and comfort of other guests, conduct injuring the establishment's reputation or dignity, the hotel's determination that his continued entertainment would be detrimental, and apparent intoxication. The evidence also established that hotel staff notified Williams that he needed to leave.
2. The deputies did not violate Williams's Fourth Amendment rights by searching the hotel room after hotel staff lawfully ejected him and invited the deputies into the room, because the room was no longer treated as Williams's private dwelling for Fourth Amendment purposes.
3. Even if the hotel had not complied with the statutory ejection procedure, the good-faith exception to the exclusionary rule would have prevented suppression because the deputies reasonably relied on information that hotel staff had told Williams to leave and on binding appellate precedent that a hotel room loses Fourth Amendment protection when its occupant has been told to leave.

Questions Presented

1. Whether hotel staff lawfully ejected Williams under section 509.141, Florida Statutes, so that he no longer retained a Fourth Amendment privacy interest in his hotel room.
2. Whether the deputies violated the Fourth Amendment by searching Williams's hotel room after hotel staff invited them inside.
3. Whether the good-faith exception to the exclusionary rule independently barred suppression of the evidence.

Disposition

affirmed