In the 1989 case Minnesota v. Olson, the U.S. Supreme Court ruled in favor of Robert E. Olson, who was charged with burglary and theft after police entered a home without a warrant where he was an overnight guest and arrested him. The court held that as an overnight guest, Olson had a legitimate expectation of privacy under the Fourth Amendment which protects against unreasonable searches and seizures by law enforcement officers. Therefore, his arrest violated his constitutional rights because it occurred without either consent or exigent circumstances to justify entering without obtaining a search warrant first.

In the dissenting opinion for Minnesota v. Olson, Justice White disagreed with the majority's view that an overnight guest has a legitimate expectation of privacy in someone else's home. He argued that while it is true that society recognizes a person’s right to privacy in their own home, this does not extend to guests who are merely present on another’s property temporarily. The Fourth Amendment should protect people and not places; therefore, he contended that the rights protected by this amendment should only apply to those who have ownership or control over the premises. In his view, an individual cannot claim violation of their Fourth Amendment rights based on search or seizure conducted at a place where they do not possess any recognized interest under property law.