Proper termination of hotel room rental agreement.

- Contraband found by police officers in the defendant's hotel room was properly seized under the Fourth Amendment because the hotel manager had the authority to terminate the defendant's rental agreement without prior notice on the ground the defendant was selling drugs from the room and creating a disturbance at the hotel, and did so before the officers went to the room; thus, the defendant no longer had a reasonable expectation of privacy in the room. The officers had to determine if anyone was in the room before the clerk could lock the door and effectuate the eviction, and thus properly entered the room to search in places where someone could be hiding and properly seized marijuana found on a table in plain view as well as marijuana located under the bed. Johnson v. State, 285 Ga. 571, 679 S.E.2d 340 (2009).

As a hotel manager had grounds to conclude that a guest was causing a disturbance, the manager was authorized to evict the guest for cause without giving advance notice under O.C.G.A. § 43-21-3.1(a). Therefore, the guest's arrest for criminal trespass was legal and the guest's false imprisonment claim against the hotel and manager was properly dismissed on summary judgment. Lewis v. Ritz Carlton Hotel Co., LLC, 310 Ga. App. 58, 712 S.E.2d 91 (2011).

Persons not paying fee for room are not guests and are not entitled to notice of eviction.

- Trial court erred by assuming that the defendants had a continuing expectation of privacy in a hotel room because a guest services agent had the authority to evict the defendants from the room once the agent learned that the defendants had checked into the hotel using a fraudulent credit card, and because the defendants had obtained the room through a fraudulent credit card that would not be honored by the credit card company, the defendants were not paying a fee for the room and were not guests within the meaning of O.C.G.A. § 43-21-1(1); therefore, the defendants could be evicted from the room for cause, and if the defendants were being evicted from the hotel for cause, under O.C.G.A. § 43-21-3.1(b), the defendants were not entitled to notice of the eviction. State v. Delvechio, 301 Ga. App. 560, 687 S.E.2d 845 (2009).