State v. Wright
2013 Ohio 4473
Ohio Ct. App.2013Background
- Shortly after midnight, police responded to a disturbance at Airport Plaza Hotel involving George Wright, who was naked, agitated, and admitted taking PCP; hotel staff reported he’d been pounding on doors and damaging property.
- Wright was removed by EMS, taken to a hospital, and arrested; officers then accompanied hotel staff to Wright’s room without a warrant or Wright’s consent to inspect alleged damages.
- Inside the room officers found drug evidence (suspected crack cocaine and PCP) in an open dresser drawer and other signs of disarray.
- Wright was indicted on multiple drug and vandalism counts and moved to suppress evidence obtained from the warrantless room search.
- The trial court granted the motion to suppress, finding Wright retained a reasonable expectation of privacy because hotel staff did not take affirmative steps to evict him or otherwise terminate his occupancy prior to the search.
- The State appealed, arguing Wright’s disruptive conduct terminated his guest status and hotel staff validly consented to the search; the appellate court affirmed the suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wright retained a Fourth Amendment privacy interest in his hotel room at time of warrantless search | Wright’s disruptive conduct terminated his guest status; hotel staff could consent to search | Wright remained a registered guest and was not affirmatively evicted; therefore he kept a privacy interest | Court held Wright retained his privacy interest; suppression proper |
| Whether hotel staff’s consent authorized police to enter absent warrant | Hotel staff’s request to check room plus disruptive conduct extinguished occupancy rights, so staff could consent | Hotel staff did not take affirmative steps to repossess or evict; staff cannot consent to police search absent eviction | Court held staff did not divest Wright of occupancy and could not lawfully authorize police entry |
| Whether police reasonably relied on hotel staff’s consent without knowing of eviction | State: officers could rely on staff’s apparent consent given circumstances | Defense: officers lacked actual or implied knowledge of any eviction; reliance unreasonable | Court held police could not reasonably rely on staff consent because no eviction occurred |
| Proper standard of review for suppression ruling | State: appellate review should examine legal application de novo after accepting trial facts | Defense: trial court’s factual findings entitled to deference; legal conclusion reviewed de novo | Court applied deferential review to facts and independent legal review; affirmed trial court |
Key Cases Cited
- Stoner v. California, 376 U.S. 483 (1964) (hotel employees cannot validly consent to police search absent guest abandonment or eviction)
- Jeffers v. United States, 342 U.S. 48 (1951) (warrantless searches require lawful consent or another exception to Fourth Amendment)
- State v. Miller, 77 Ohio App.3d 305 (8th Dist. 1991) (hotel management may lawfully consent only where guest has surrendered or no longer rents the room)
- State v. Preztak, 181 Ohio App.3d 106 (8th Dist. 2009) (standard of review for suppression: factual findings receive deference; legal issues reviewed de novo)
- Allen v. United States, 106 F.3d 695 (6th Cir. 1997) (manager’s affirmative act to lock guest out can divest guest of occupancy and permit consented search)
- Winand v. State, 116 Ohio App.3d 286 (7th Dist. 1996) (trial court as factfinder is best positioned to resolve credibility in suppression hearings)