MN law that requires identifying information on renters is third party information and voluntary disclosure doesn’t offend Patel

Defendant rented a motel room in Minnesota, and state law requires the hotelier to gather certain basic identifying information about the renter. The police came and inquired of the hotel. They ran defendant’s information and learned that he’d been convicted of fraud and drug offenses. They then attempted a knock-and-talk on the hotel room. He refused consent, but the police saw from the door what appeared to be an identity theft operation. They obtained a search warrant. Defendant’s reliance on Patel v. City of Los Angeles is misplaced. This is basic third party information under Miller and Smith, and he had no reasonable expectation of privacy in the information. The state constitution does not compel a different result. State v. Leonard, 2019 Minn. App. LEXIS 45 (Feb. 4, 2019).