Landlord has no legitimate "right of privacy" in tenants' mailboxes
C. Michael Doherty sued the City of East Lansing after he was fined several thousand dollars for renting apartments in a manner that resulted in over-occupancy and violation of City zoning codes. Doherty's repeated violations were discovered when City employees identified multiple tenant names on the interior surface of mailbox lids. He claimed that the City's viewing of the mailbox lids violated his Fourth Amendment protections against unreasonable searches.
The Court held that if anyone enjoyed a privilege based on a reasonable right of privacy in mailbox identifications, it was the tenants, not the landlord. And it expressed the opinion that, in fact, no one reasonably thought their mailbox identification was private information, given its accessiblity to anyone.