The Third Circuit Court of Appeals issued a precedential ruling that hotel guests lose any reasonable expectation of privacy in their rooms once checkout time passes, affirming a lower court's decision to deny a motion to suppress evidence obtained from a post-checkout hotel room search.
In *United States v. Ryan Mendoza* (3d Cir. 2026), the appeals court upheld the U.S. District Court for the Western District of Pennsylvania's denial of defendant Ryan Mendoza's motion to suppress evidence. The case centers on whether Mendoza maintained Fourth Amendment protections in his hotel room five hours after the posted checkout time.
Circuit Judge Thomas Ambro, writing for the three-judge panel that included Judges Restrepo and McKee, held that Mendoza "failed to show he had a reasonable expectation of privacy in that hotel room" after checkout time had passed. The court concluded that "five hours after checkout time, any expectation of privacy Mendoza had was not objectively reasonable."
The facts underlying the case began on February 24, 2021, when Mendoza checked into a Pittsburgh hotel around 1:00 a.m. for a two-night stay covering February 23-24 and February 24-25. His receipt indicated a departure date of February 25. The hotel clearly posted checkout time as noon on signs behind the front desk and on the back of each guest room door.
The hotel's standard practice allowed guests to check out either by visiting the front desk or simply leaving without notification. Key cards were programmed to deactivate two hours after checkout time. When Mendoza failed to check out by noon on February 25, the hotel's system automatically added him to a "due-out" list that staff use to verify room vacancy.
Around 2:00 p.m. on February 25, five hours after the posted checkout time, the hotel manager checked Mendoza's room and observed personal items but no luggage. This observation led to the discovery of evidence that formed the basis of the criminal charges against Mendoza.
The district court, presided over by Judge Arthur J. Schwab, initially denied Mendoza's suppression motion. Mendoza appealed to the Third Circuit, which heard the case under Local Appellate Rule 34.1(a) after submission on November 13, 2025.
The Third Circuit's analysis focused on the objective reasonableness standard for Fourth Amendment expectations of privacy. The court examined whether a hotel guest could reasonably expect privacy in a room after the clearly posted checkout time had passed and the guest had not extended their stay or communicated with hotel staff.
The appeals court emphasized that privacy expectations must be objectively reasonable under the circumstances. The opinion suggests that the combination of factors—the posted checkout time, the guest's failure to check out or extend the stay, and the significant time gap of five hours—eliminated any reasonable privacy expectation.
This precedential ruling will have implications for Fourth Amendment jurisprudence in the Third Circuit, which covers Pennsylvania, New Jersey, Delaware, and the Virgin Islands. The decision provides law enforcement and courts with clearer guidance on when hotel room searches may proceed without violating constitutional protections.
The case highlights the intersection of commercial lodging practices and constitutional privacy rights. Hotels routinely need to determine room occupancy status for cleaning, maintenance, and new guest arrivals. The ruling suggests that clearly posted policies and reasonable time limits provide sufficient notice to guests about when their privacy expectations end.
Legal practitioners representing clients in similar circumstances will need to consider the timing and communication factors that the Third Circuit found dispositive. The decision indicates that guests who overstay posted checkout times without hotel permission or communication cannot maintain reasonable privacy expectations.
The ruling also underscores the importance of hotel policies being clearly communicated to guests. The court noted that checkout time was posted "on the back of each guest room door, and usually on a plaque behind the front desk," suggesting that adequate notice is crucial to the analysis.
Defense counsel Ryan R. Smith represented Mendoza in the appeal, while Assistant U.S. Attorneys Adam N. Hallowell and Laura S. Irwin argued for the government. The case was filed as No. 25-1154 and stems from the underlying criminal case No. 2:21-cr-00503-001 in the Western District of Pennsylvania.
The Third Circuit's opinion, filed January 8, 2026, joins a body of federal appellate case law addressing privacy expectations in temporary lodging situations. The precedential nature of the decision means it will be binding authority for district courts within the Third Circuit and persuasive authority for other federal courts addressing similar fact patterns.
The practical impact extends beyond criminal law to civil litigation involving hotel searches, insurance investigations, and regulatory enforcement actions where privacy expectations in commercial lodging may be at issue.