State v. Houghtaling

Summary

The court affirmed the judgment upholding denial of suppression. It held that the defendant failed to establish a subjective expectation of privacy in property he owned but had leased to another person, that police had reasonable suspicion to detain him, and that the circumstances supplied probable cause for his arrest and subsequent statement. The court expressly rejected the inflexible three-factor approach previously used to assess subjective privacy expectations, while leaving an alternative fruit-of-the-poisonous-tree question unresolved.