PA: Having hotel room key without anyone being registered in room doesn’t show standing

Defendant in speaking to the police said that he was staying in 111 of the Knights Inn hotel, and he showed a key card. When the officer turned away the key was hidden in the car. Later the police retrieved the card and it wasn’t for 111–it was for 231. Checking the hotel records, however, he was not registered in 231, and nobody was. “Based upon this evidence, we agree with the Commonwealth that Appellee failed to demonstrate a subjective expectation of privacy in room 231 of the Knights Inn, much less one that society would accept as reasonable. Appellee produced no evidence at the suppression hearing indicating that he was a hotel guest of room 231. That is, he presented no evidence that he was properly occupying room 231, let alone that he had rented the room and, if so, for what period of time.” Commonwealth v. Williams, 2017 PA Super 183, 2017 Pa. Super. LEXIS 430 (June 13, 2017).*