People v. Turner

This case present question as to whether trial court properly denied defendant’s motion to suppress warrantless police seizure of his clothes located in plain view in trauma room in emergency department of hospital. Record showed that: (1) defendant came to hospital with gunshot wound to his thigh, and that after defendant was taken to trauma room, which contained four walls and door, nurse gathered defendant’s bloody pants and underwear and placed said clothing in clear bag in trauma room; and (2) nurse’s notes indicated that after police arrived in defendant’s trauma room, defendant agreed to police request to look at said clothing and agreed with officer’s statement that officer would be taking said clothing with him. Basis of defendant’s Fourth Amendment claim was that he had reasonable expectation of privacy in his trauma room, such that police were required to obtain warrant to search said room. Appellate Court, in affirming trial court, held that defendant did not have legitimate expectation of privacy in instant trauma room, where defendant had no ownership interest in said room and had no ability to exclude others from said room. Appellate Court also noted that trauma room was only temporary placement for defendant, where medical staff could assess his injuries and provide initial medical care.