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No Expectation of Privacy in Hotel Records

The Minnesota Court of Appeals ruled in State v. Leonard that a hotel guest has no reasonable expectation of privacy in information they voluntarily provide to a hotel operator.

In Leonard, the appellant, Mr. Leonard, rented a room at a hotel in Bloomington. In doing so, he provided his driver's license information to the hotel clerk. Police officers arrived at the hotel and requested a guest list from the hotel's registration records. The hotel clerk provided officers with the guest list, showing Mr. Leonard as a current guest. Officers went to Mr. Leonard's room and knocked on the door. After some interactions and observations, Mr. Leonard was placed under arrest and charged multiple counts of check forgery.READ MORE...

Mr. Leonard brought a motion to suppress all evidence found in his hotel room, arguing that it was recovered as part of an illegal search of his guest information. He argued that Minnesota Statute §327.12 was unconstitutional because it required hotels to comply with warrantless searches of their registration records. He also argued that he did not voluntarily supply any information, but was instead required to do so if he wanted to rent a hotel room in Minnesota.

The court of appeals disagreed with Mr. Leonard. Relying on prior case law, the court of appeals ruled here that a person has no reasonable expectation of privacy in information they voluntarily turn over to others. No one forced Mr. Leonard to provide his identifying information. While acknowledging that to rent a hotel room a person must provide certain information, a choice still exists to rent or not rent a hotel room. The court held that none of Mr. Leonard's Fourth Amendment rights were violated by this warrantless search of the hotel registration records.

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