State v. LeonardAnnotate this Case
The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room.
Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress.