USA v. Ryan Mendoza
Split Score
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Case Summary
Disposition
Affirmed
The Third Circuit affirmed the denial of Ryan Mendoza’s motion to suppress evidence found in his hotel room, holding that any expectation of privacy he had ended well before officers searched the room—five hours after the posted noon checkout time. Because his expectation was not objectively reasonable, the warrantless search did not violate the Fourth Amendment.
Circuit Split Identified
Legal Issue
Whether a hotel guest retains a reasonable expectation of privacy in a room for a short 'grace period' after the posted checkout time when the hotel’s practices may tolerate late departure.
Circuit Positions
Grace period may preserve a reasonable expectation of privacy depending on hotel practices or communications.
No grace period—privacy interest terminates at the posted checkout time (bright-line rule).
Undecided; declined to reach the broader grace-period question while finding no expectation five hours after checkout.
Conflict Summary
Several circuits recognize a potential grace-period exception that can preserve a guest’s Fourth Amendment privacy interest after checkout time if hotel customs or communications would lead a reasonable guest to believe a brief overstay is permitted. The Eleventh Circuit rejects any such exception, adopting a bright-line rule that the expectation of privacy ends precisely at checkout. The Third Circuit in this opinion resolves the case on the facts (five hours after checkout) and expressly declines to take a definitive position, leaving the question open.