Summary
The United States Court of Appeals for the Third Circuit held that Ryan Mendoza lacked an objectively reasonable expectation of privacy in his hotel room when police searched it five hours after the posted checkout time. The court concluded that the hotel had exclusive possession of the room by then, notwithstanding Mendoza's failure to affirmatively check out, and affirmed the denial of his motion to suppress.
Topics
Practice areas
Questions Presented
- Whether a hotel guest retains an objectively reasonable expectation of privacy in a hotel room five hours after the designated checkout time when the guest has not affirmatively checked out.
- Whether the warrantless police search of Mendoza's former hotel room violated the Fourth Amendment.
Holdings
- A hotel guest's expectation of privacy in a room five hours after the designated checkout time is not objectively reasonable under the circumstances presented, even if the guest did not affirmatively check out at the front desk.
- The warrantless search did not violate Mendoza's Fourth Amendment rights because he lacked a legitimate, objectively reasonable expectation of privacy in the room when it was searched.
Key quotations
“Five hours after checkout time, any expectation of privacy Mendoza had was not objectively reasonable.” (2)
“However, the many circuits to have confronted the issue unanimously hold that the expectation lapses after checkout time.” (5)
“An expectation of privacy is legitimate only if it is objectively reasonable.” (8)
“As such, the police’s search of that room did not violate Mendoza’s Fourth Amendment rights.” (8)
Factual background
Mendoza rented a Pittsburgh hotel room for a two-night stay, with a receipt stating a February 25 departure date and hotel signage specifying noon checkout. He had not checked out by noon on February 25, and hotel staff treated the room as vacant, deactivated the room keys, and later found a backpack containing wrapped packages of white powder. Police entered the room without a warrant around 5:20 p.m., approximately five hours after checkout time, after the hotel manager confirmed that the room was vacant, Mendoza no longer had possession of it, and he would not be permitted to return.
Procedural history
Mendoza was charged in the United States District Court for the Western District of Pennsylvania and moved to suppress evidence found in his hotel room. The District Court denied the motion, concluding that Mendoza lacked a reasonable expectation of privacy in the room after checkout time. The Third Circuit affirmed.