CT: Jumping out of a hotel room window in flight from the police was abandonment of the room

Defendant jumped out a hotel room window in flight from the police, and this was an abandonment of the room. He also abandoned a pair of socks on the roof the hotel. State v. Jackson, 304 Conn. 383, 40 A.3d 290 (2012):

The defendant had no reasonable expectation of privacy in the hotel room or in the personal effects that he left there after he jumped out of the hotel window, and even if he had not manifested a subjective intent to abandon the hotel room, the New York City police officers’ initial entry into the hotel room was justified under the emergency exception to the warrant requirement because they reasonably could have believed that there might be other persons in the hotel room who were injured or who needed assistance and, therefore, they were not required to obtain a search warrant before seizing the defendant’s clothes for safekeeping pursuant to their community caretaking function; furthermore, the mere transfer of the items from the New York City police to the New Haven police did not violate the defendant’s fourth amendment rights, the transfer having involved no additional intrusion into the defendant’s privacy and the subsequent forensic testing of the defendant’s pants and belt having been performed pursuant to a search warrant.

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