Adams, Randy Dale, PD-0969-17

Background

On July 10, 2014, Irving police requested and the Motel 6 front desk voluntarily handed over the motel guest registry to uniformed officers without any individualized suspicion.
Officers checked the registry entries against warrants and discovered that Randy Dale Adams was a guest and had outstanding misdemeanor warrants.
Officers located Adams, obtained consent to search his room, and found methamphetamine; Adams was charged with possession of a controlled substance.
Adams moved to suppress the evidence, arguing the suspicionless review of the hotel registry violated Fourth Amendment protections; the trial court granted the motion.
The State appealed pursuant to Texas Code Crim. Proc. art. 44.01(a)(5); the Dallas Court of Appeals reversed, holding Adams had no reasonable expectation of privacy in the registration under the third‑party doctrine.
Appellee filed a Petition for Discretionary Review to the Texas Court of Criminal Appeals raising (1) whether hotel registry privacy claims present a novel issue; (2) conflict with U.S. Supreme Court precedent; and (3) jurisdictional defect in the State’s notice of appeal (signature issue).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a hotel guest has a reasonable expectation of privacy in motel registration records	Adams: a guest retains a privacy interest in registration information; the third‑party doctrine should not permit suspicionless fishing of sensitive records	State: registration information is voluntarily disclosed to a third party (motel) and is thus not protected under the third‑party doctrine	Court of Appeals: held no reasonable expectation of privacy; registry subject to third‑party doctrine, trial court abused discretion in suppressing evidence
Whether the third‑party doctrine applies to suspicionless, non‑targeted requests for registries	Adams: doctrine should be limited where sensitive information is obtained without any individualized suspicion	State: doctrine applies broadly to information shared with third parties	Court of Appeals: applied third‑party doctrine without imposing a suspicion requirement
Whether City of Los Angeles v. Patel and related Supreme Court concerns about registries affect this case	Adams: Patel signals constitutional concerns with suspicionless registry searches and supports review	State: distinguishes Patel or finds it inapplicable	Court of Appeals: did not rely on Patel; upheld third‑party doctrine as controlling
Whether the State’s notice of appeal was procedurally defective for lack of the elected DA’s signature	Adams: notice was invalid because the elected DA did not personally sign or explicitly authorize the First Assistant to sign; thus appellate jurisdiction is lacking	State: relied on notice as filed by First Assistant to invoke appeal	Court of Appeals: proceeded to decision; Adams asserts this departure warrants supervisory review by Court of Criminal Appeals

Key Cases Cited

135 S. Ct. 2443 (City of Los Angeles v. Patel) (discusses constitutional problems with suspicionless on‑demand hotel registry inspections)
442 U.S. 735 (Smith v. Maryland) (establishes third‑party doctrine for information conveyed to third parties)
425 U.S. 435 (United States v. Miller) (holds business records held by third parties are not protected by the Fourth Amendment)
389 U.S. 347 (Katz v. United States) (articulates expectation of privacy test under the Fourth Amendment)
132 S. Ct. 945 (United States v. Jones) (concurrences raise concerns about third‑party doctrine in the digital age)
517 S.W.3d 112 (Hankston v. State) (Texas Crim. App. application of third‑party doctrine to CSLI and expectation‑of‑privacy analysis)
477 S.W.3d 321 (Ford v. State) (Texas Crim. App. discussion of third‑party doctrine in the context of location information)
829 S.W.2d 805 (State v. Muller) (procedural requirements for state notices of appeal and signature rules)
830 S.W.2d 605 (State v. Shelton) (further discussion of signature/authorization requirements for appeals by state prosecutors)