CA7: Def’s car with his phone in it parked repeatedly outside a house supported PC to search that place

The repeated presence of defendant’s car and cell phone at the place searched under the warrant added to the probable cause that that was a place where evidence could be found. It wasn’t misleading to the USMJ to not tell him about the other potential addresses of the defendant. United States v. Jones, 2014 U.S. App. LEXIS 15950 (7th Cir. August 18, 2014).*

Defendant had no standing to complain of a seizure of a bag of drugs dropped by someone else in the stairway of a public housing project. United States v. Rodriguez-Irizarry, 2014 U.S. Dist. LEXIS 114641 (D. P.R. August 18, 2014).*

Defendant had no standing to object to an officer approaching him parked in a defunct car wash bay just because his uncle owned it. Plain view sustained. United States v. Evans, 2014 U.S. Dist. LEXIS 115227 (E.D. Mo. July 30, 2014).*