United States v. Jamil Murray, 821 F.3d 386

Police investigating prostitution/drug tip saw a green Cadillac linked to Room 302 at Neshaminy Motor Inn; the car was registered to Jamil Murray, who rented rooms at a nearby Knights Inn.
Officers knocked on Room 302; a woman in lingerie (Jessica Burns) answered, initially told officers to go away, then opened after an officer identified himself.
Burns told officers she was a prostitute who worked for the room renter (Murray) and said she had earlier called 911 for help (using an alias).
Murray later entered Room 302; officers recognized him, performed a frisk supported by their suspicion he might be armed, and—per the officers—obtained his consent to remove items (cash, phone, keys, lanyard).
Evidence from Room 302 and items seized from Murray supported warrants to search Rooms 157 and 158 and the Cadillac; Room 157 yielded over 192 grams of crack cocaine.
Murray pleaded guilty to drug offenses but preserved his right to appeal the denial of his suppression motion; the district court found Burns had common or apparent authority to consent and that the frisk and subsequent seizures were lawful.

Issue	Murray's Argument	Government's Argument	Held
Whether officers’ entry into Room 302 violated the Fourth Amendment	Burns lacked actual or apparent authority; her consent was coerced	Burns had common or, at minimum, apparent authority and voluntarily consented	Entry lawful: Burns had common/apparent authority; consent voluntary
Whether information from Burns was admissible or "fruit" of illegal entry	Statements were fruit of unlawful entry and must be suppressed	Statements admissible because entry was lawful via consent	Statements admissible; not fruit of illegal search
Whether frisk of Murray violated Terry when conducted in a motel room	Terry frisk in a dwelling-like setting is inapplicable; frisk unlawful	Officers had reasonable suspicion Murray (a suspected drug dealer) was armed and dangerous	Frisk lawful: reasonable suspicion existed; Terry applied to protect officers
Whether items taken from Murray were seized lawfully	Consent to seizure was coerced / not given	Corporal testified he obtained Murray's consent to remove items; lawful consent	Seizures lawful: district court credited officer’s testimony; not clearly erroneous

Schneckloth v. Bustamonte, 412 U.S. 218 (consent to search is a fact question evaluated for voluntariness)
Matlock v. United States, 415 U.S. 164 (third-party common authority can justify consent to search)
Illinois v. Rodriguez, 497 U.S. 177 (entry valid where officers reasonably believe third party has common authority)
Terry v. Ohio, 392 U.S. 1 (officer may frisk for weapons if reasonably suspects person is armed and dangerous)
Ybarra v. Illinois, 444 U.S. 85 (a frisk requires particularized suspicion directed at the person frisked)
Florida v. Jardines, 133 S. Ct. 1409 (physically intruding on private property to gather information is a Fourth Amendment search)
Stoner v. California, 376 U.S. 483 (hotel guest has a legitimate expectation of privacy in rented room)