Minnesota v. Carter

The police received a tip from an anonymous informant that a drug transaction was transpiring in a first floor apartment. Based on the tip, an officer went to the apartment building and, while standing in an area frequently used by the public, he peered into the apartment through a crack in the blind and observed Johns and Crater (defendant) putting white powder into bags. He called headquarters, requested that a warrant be obtained, and an eventual search pursuant to the warrant revealed that the occupants of the apartment had been bagging cocaine. The apartment belonged to a woman who was present when the drugs were being packaged. Johns and Carter were from another state, had only been at the apartment for a few hours, and did not have a preexisting relationship with the owner of the apartment, who was simply allowing them to use the apartment to bag their drugs in exchange for cocaine. At trial, Carter claimed that his Fourth Amendment rights were violated and requested that the drug evidence be suppressed. The trial court denied the motion, holding that Carter was not an overnight social guest and thus could not claim Fourth Amendment protections. The trial court also found that the police officer’s observations prior to obtaining the warrant did not constitute a Fourth Amendment search. The state supreme court reversed, holding that Carter had standing to claim Fourth Amendment protections and that the officer’s observations constituted a search.