Christopher Major v. Commonwealth of Kentucky, 2024-CA-0026

Christopher Major was found in a motel room at the Days Motor Lodge after a lodge employee reported him as a trespasser.
Lexington police entered the motel room (not registered to Major) without a warrant after obtaining entry from lodge staff; Major was found in the bathroom smoking crack cocaine.
Major was arrested for trespassing, Mirandized, and made incriminating statements related to theft charges.
Major moved to suppress his statements, arguing the warrantless entry and arrest were improper.
The trial court found Major had no reasonable expectation of privacy as a trespasser, denied the suppression motion, and sentenced him to 10 years after a conditional guilty plea.
On appeal, Major contested the suppression ruling, asserting a privacy interest in the motel room.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether warrantless entry into motel room violated the Fourth Amendment	Major: Had privacy interest in motel room	Commonwealth: Major was trespassing, so no privacy	No privacy interest; entry did not violate Fourth Amendment
Whether statements should be suppressed due to unlawful entry	Statements were tainted by illegal arrest	Lawful entry meant confessions untainted	No suppression; statements admissible

Katz v. United States, 389 U.S. 347 (U.S. 1967) (establishes warrantless searches are per se unreasonable barring exceptions)
Rawlings v. Kentucky, 448 U.S. 98 (U.S. 1980) (must have legitimate expectation of privacy for Fourth Amendment protection)
Minnesota v. Carter, 525 U.S. 83 (U.S. 1998) (expectation of privacy must be one recognized by society)
Smith v. Maryland, 442 U.S. 735 (U.S. 1979) (society must recognize individual's subjective privacy expectation as reasonable)
Stoner v. California, 376 U.S. 483 (U.S. 1964) (guests in hotel rooms have Fourth Amendment protection)
Blades v. Commonwealth, 339 S.W.3d 450 (Ky. 2011) (privacy interest ends when guest's right to occupancy is terminated)