Minnesota v. Carter

Acting on an anonymous tip about a drug transaction, an officer stood in an area frequently used by the public outside a first-floor apartment and, peering through a gap in the blinds, saw Carter (defendant) and another man bagging cocaine with the apartment's owner present; a subsequent warrant-based search confirmed the drug activity. Carter and his companion were from out of state, had been at the apartment only a few hours, had no preexisting relationship with the owner, and were there solely so the owner could let them bag drugs in exchange for cocaine; at trial, Carter argued his Fourth Amendment rights were violated and sought suppression, but the trial court held Carter was not an overnight social guest and therefore lacked Fourth Amendment protection, and separately found the officer's pre-warrant observations were not themselves a Fourth Amendment search. The state supreme court reversed on both points.