State of Minnesota v. Leona Rose deLottinville
877 N.W.2d 199
Minn. Ct. App.2016Background
- Respondent Leona deLottinville, staying at DR's residence as a short-term social guest, was subject to an arrest warrant.
- Meeker County Drug Task Force officers went to DR's residence with the warrant and planned to arrest respondent upon locating her.
- Respondent was seen by an officer through a glass patio door in the lower unit and was arrested when the officer entered the unlocked door from the back of the house.
- Marijuana and a bong were observed in plain view during the arrest, leading to subsequent searches and a broader drug investigation at the residence.
- Respondent was charged with fifth-degree possession of methamphetamine, hydrocodone, and possession of drug paraphernalia; the district court suppressed due to a privacy-based dismissal.
- The state appealed, arguing the arrest and entry were lawful under a valid warrant and Payton-based authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May police enter a third-party home to arrest a visitor with a valid warrant? | State argues arrest warranted entry; guest has no standing to block entry. | DeLottinville argues entry violated privacy rights if not authorized by warrant as to her home. | Entry lawful; arrest permitted under warrant and Payton framework. |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (arrest warrant justifies entry into arrestee's dwelling)
- Steagald v. United States, 451 U.S. 204 (U.S. 1981) (arrest warrant for third party does not justify entering home of non-arrestee)
- United States v. Clifford, 664 F.2d 1090 (8th Cir. 1981) (arrest of visitor in another's home under warrant may be lawful; Payton-based entry possible)
- State v. Couillard, 641 N.W.2d 298 (Minn. App. 2001) (standing to challenge entry by a visitor; addressing; not controlling for arrest entry of guest)
- In re Welfare of B.R.K., 658 N.W.2d 565 (Minn. 2003) (short-term guest privacy/standing considerations)
- State v. Patricelli, 324 N.W.2d 351 (Minn. 1982) (commentary on need for search warrant if residence not defendant's home; dicta)
- United States v. Risse, 83 F.3d 212 (8th Cir. 1996) (cites reasoning distinguishing Steagald where arrestee present via guest in home)
- State v. Olson, 634 N.W.2d 224 (Minn. App. 2001) (search/fruit-of-poisonous-tree principles applied to suppression)