U.S. v. Procknow

In prosecution on charge of theft of govt. money and aggravated identity theft related to defendant’s filing of fraudulent tax returns, Dist. Ct. did not err in denying defendant’s motion to suppress evidence obtained pursuant to police officer’s warrantless entry into defendant’s hotel room that occurred after his arrest in hotel lobby. While defendant argued that he had legitimate expectation of privacy in hotel room that was registered to his girlfriend, search was not improper where, at time of search, police had reasonable belief that both defendant and his girlfriend had been ejected from hotel by hotel management following their arrests. Moreover, instant ejection was justified, where defendant’s violent arrest in hotel lobby during his attempt to flee constituted "disturbance” under Minnesota law.