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March v. State

Citations: 725 So. 2d 472; 1999 Fla. App. LEXIS 1604; 1999 WL 76148Docket: No. 98-2174

Court: District Court of Appeal of Florida; February 18, 1999; Florida; State Appellate Court

Narrative Opinion Summary

In the case of Minnesota v. Carter, the court affirmed that defendants who are merely guests on premises for commercial transactions lack standing to challenge the seizure of evidence due to a lack of reasonable expectation of privacy. This conclusion aligns with prior rulings, specifically referencing United States v. Salvucci, which emphasizes that only those whose Fourth Amendment rights have been violated can invoke the exclusionary rule. The court reiterated that suppression of evidence from a Fourth Amendment violation is only available to individuals whose rights were directly infringed by the search, as established in Alderman v. United States and further supported by Jones v. State. The court defined a "search" as an infringement on an expectation of privacy that society deems reasonable. The opinion was concurred by Justices Sharp, Thompson, and Antoon.

Legal Issues Addressed

Definition of a Search Under Fourth Amendment

Application: A 'search' is defined as an infringement on an expectation of privacy deemed reasonable by society, guiding the assessment of privacy violations.

Reasoning: The court defined a 'search' as an infringement on an expectation of privacy that society deems reasonable.

Fourth Amendment Exclusionary Rule

Application: The exclusionary rule can only be invoked by individuals whose Fourth Amendment rights have been directly violated, reinforcing that guests without privacy expectations cannot suppress evidence.

Reasoning: This conclusion aligns with prior rulings, specifically referencing United States v. Salvucci, which emphasizes that only those whose Fourth Amendment rights have been violated can invoke the exclusionary rule.

Standing to Challenge Seizure of Evidence

Application: The court determined that defendants who are merely guests on premises for commercial transactions do not have standing to challenge the seizure of evidence due to a lack of reasonable expectation of privacy.

Reasoning: In the case of Minnesota v. Carter, the court affirmed that defendants who are merely guests on premises for commercial transactions lack standing to challenge the seizure of evidence due to a lack of reasonable expectation of privacy.

Suppression of Evidence from Fourth Amendment Violation

Application: Suppression of evidence is limited to those whose rights were directly infringed by a search, as supported by precedent cases Alderman v. United States and Jones v. State.

Reasoning: The court reiterated that suppression of evidence from a Fourth Amendment violation is only available to individuals whose rights were directly infringed by the search, as established in Alderman v. United States and further supported by Jones v. State.