Minnesota v. Carter
Citation and Court
525 U.S. 83 (1998) — Supreme Court of the United States
Facts
An officer looked through a gap in window blinds and observed Carter and another person bagging cocaine in someone else’s apartment. Carter and his associate were short-term guests who were using the apartment solely to package drugs for a fee. Carter moved to suppress the officer’s observations.
Issue
Whether a person who is present in another’s home solely for a commercial purpose and for a short time has a legitimate expectation of privacy sufficient to invoke Fourth Amendment protection.
Holding
Carter and his associate had no legitimate expectation of privacy in the apartment; they were purely commercial, short-term visitors with no personal connection to the home.
Rule / Doctrine
The Fourth Amendment protects persons, not places, but only when they have a legitimate expectation of privacy in the area searched. Overnight social guests may have such an expectation (Minnesota v. Olson), but purely commercial, temporary visitors engaged in a business transaction do not. The more attenuated the relationship to the home, the less likely a cognizable Fourth Amendment interest exists.
Significance
Drew a sharp line between social guests with Fourth Amendment standing and commercial transients who lack it. A defendant must show a personal connection to the premises that goes beyond mere presence for a brief, commercial purpose.