State of Arizona v. Robin Peoples, 240 Ariz. 244

Robin Peoples spent the night at his girlfriend D.C.’s studio apartment and used his cell phone to record sexual activity; D.C. was found dead the next morning.
Peoples briefly left the apartment to direct paramedics and left his phone in the bathroom; he later asked officers at the door to retrieve it.
Officer Travis Mott found the unprotected phone in the bathroom, turned it on, saw a paused video of D.C. and played a recording showing Peoples having sex with an apparently unresponsive D.C.
After viewing the video, officers detained and Mirandized Peoples and questioned him; he admitted to filming and said D.C. "probably was [dead]" when they had sex.
Peoples was charged with necrophilia and sexual assault, moved to suppress the video and statements as products of an unlawful warrantless search, and the trial court granted suppression; the court of appeals reversed.
The Arizona Supreme Court granted review to decide whether Peoples had a legitimate expectation of privacy in the phone and/or as an overnight guest and whether the good-faith exception applied.

Issue	State's Argument	Peoples' Argument	Held
1) Did Peoples have a legitimate expectation of privacy in the cell phone?	No; phone was not in Peoples’ immediate control and was not passcode-protected.	Yes; Riley protects phone data and lack of passcode does not negate privacy; phone was not abandoned.	Held: Peoples had a reasonable expectation of privacy in his phone.
2) Did Peoples retain overnight-guest privacy in D.C.’s apartment when the phone was searched?	No; he voluntarily left, lived next door, had few belongings there, and D.C. died so guest status ended.	Yes; his departure was to assist paramedics, he asked officers to retrieve the phone, and social norms permit maintaining guest status until belongings are retrieved.	Held: Peoples remained an overnight guest with a legitimate expectation of privacy under the totality of the circumstances.
3) Does the good-faith exception to the exclusionary rule permit admission of the phone/video?	Yes; officers acted reasonably in treating the phone as belonging to the decedent.	No; officer lacked an objectively reasonable belief the phone belonged to D.C. and knew Peoples had been an overnight guest.	Held: Good-faith exception does not apply; suppression proper.

Riley v. California, 134 S. Ct. 2473 (2014) (warrant generally required to search cell phone data; phones hold extensive private information)
Minnesota v. Olson, 495 U.S. 91 (1990) (overnight guest has reasonable expectation of privacy in host's home)
Rakas v. Illinois, 439 U.S. 128 (1978) (Fourth Amendment protections depend on legitimate expectation of privacy, not standing)
Davis v. United States, 564 U.S. 229 (2011) (good-faith exception to exclusionary rule when officers act with objectively reasonable belief their conduct is lawful)
United States v. Leon, 468 U.S. 897 (1984) (foundation for the good-faith exception)
Arizona v. Gant, 556 U.S. 332 (2009) (limits on search-incident-to-arrest doctrine)