Minnesota V. Carter Case Summary

Minnesota v. Carter (1998)
Facts
In Eagan, Minnesota, Wayne Carter and Melvin Johns were observed by a police officer through a gap in closed blinds of a window after an informant gave the officer a tip. Carter and Johns were bagging cocaine and after leaving the apartment, the officer arrested them. Carter and Johns argued the officer’s observation through the window was an unreasonable search in violation of the Fourth Amendment. The trial court dismissed the argument, and the Minnesota Court of Appeals held Carter did not have standing because he used the apartment for business purposes when packaging the drugs. The Minnesota Supreme Court reversed, stating Carter and Johns had a right to Fourth Amendment protection because they had an …show more content…
The Fourth Amendment suggests the protection only extends to people in their homes, but the Court held previously in Minnesota an overnight guest in a house has an expectation of privacy protected by the Fourth Amendment. Jones held Jones’ Fourth Amendment rights were violated when the apartment he was staying in for a night was searched. However, Jones could not be used as precedent to declare anyone on the premises of a search can challenge its legality because Rakas rejected the decision in Jones. An overnight guest in a home can claim Fourth Amendment protection, but an individual present in the household with the consent of the homeowner cannot. Carter and Johns were not overnight guests and were only in the house to complete a business transaction for a couple of hours. Therefore, due to the business reason Carter and Johns were there, the short amount of time they spent at the apartment, as well as the lack of a relationship between the owner of the apartment and Carter and Johns, the Court ruled their Fourth Amendment rights were not violated. In her dissenting opinion, Justice Ginsburg argued guests invited into an individual’s home should be afforded the same protections against unreasonable searches and seizures as the

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