Cal.2d: No REP in a hospital room with an open door and nurses coming and going

Officers did not need a search warrant to enter her hospital room to talk to her about her still birth or whether she killed the fetus. There was no reasonable expectation of privacy at the time of the entry. She also objectively consented to the officers remaining there and talking to her.
In re M.S., 2019 Cal. App. LEXIS 203 (2d Dist. Mar. 11, 2019):

Moreover, the officers’ entry into M.S.’s hospital room did not violate her reasonable expectation of privacy. (People v. Brown (1979) 88 Cal.App.3d 283, 290-292.) Detectives Brice and McGehee were dressed in plain clothes, the hospital room door was open, a nurse was present at some point, and the detectives knocked and announced their presence. Under the circumstances, the hospital room was within the joint dominion of the hospital and M.S. (Id. at p. 291.) “[N]o Fourth Amendment violation occurs when a nurse permits an officer to enter a sentient patient’s hospital room for purposes unrelated to a search, [and] the patient does not object to the visit.” (Id. at p. 292.) At the time the officers entered M.S.’s hospital room, they were attempting to determine whether “a medical event” [still birth] or a crime had occurred. M.S. also did not object to the officers’ presence.