Joseph Ecker robbed a gasoline station in Minneapolis and shot the manager to death. Roger Olson drove the getaway car. Ecker was soon arrested and the murder weapon recovered. The next day, police got a tip as to Olson's whereabouts and surrounded the duplex where he was staying with the two women who resided there. Officers entered without consent or warrant and arrested Olson, who made incriminating statements that he later sought to suppress as fruits of the entry and search of his hosts' home. The U.S. Supreme Court ruled that he could do so.
The court cited to its decision in Payton v. New York, which held that a warrantless, nonconsensual, non-exigent entry into a private home to make an arrest violates the Fourth Amendment. As to Olson's ability to claim the benefit of this rule in someone else's home, the court found that because he was an overnight guest, he had an expectation of privacy that society would consider legitimate. The court said this:
"Staying overnight in another's home is a longstanding social custom that serves functions recognized as valuable by society. We will all be hosts and we will all be guests many times in our lives. From either perspective, we think that society recognizes that a houseguest has a legitimate expectation of privacy in his host's home. Because Olson's expectation of privacy in the Bergstrom home was rooted in understandings that are recognized and permitted by society, it was legitimate, and Olson can claim the protection of the Fourth Amendment." (Minnesota v. Olson)
The court added that there was no exigency to excuse the warrant requirement because (1) Olson was known not to be the murderer; (2) the murder weapon had already been recovered; (3) officers knew the occupants of the residence were friends of Olson and were not in any danger; (4) officers had the house surrounded; and (5) it was evident the suspect could not escape. Since the entry was not justified by exigency, consent, or warrant, it was unconstitutional under Payton. Olson was therefore permitted to suppress his statement.
The Olson case stands for the rule that an overnight guest will normally be allowed to maintain a suppression motion or a civil rights lawsuit based on an alleged unlawful entry or search of his host's residence.