Four people had expectation of privacy in storage unit of one

Four plaintiffs retained an expectation of privacy in a storage unit rented by one where they agreed to put their stuff there. Garcia v. Dykstra, 260 Fed. Appx. 887, 2008 FED App. 0074N (6th Cir. 2008).

Telling a suspect police would seek a search warrant if consent was not granted was not coercive because, if they have probable cause, they have the ability to get a search warrant. United States v. Giles, 2008 U.S. Dist. LEXIS 7177 (M.D. Pa. January 31, 2008)*:

The court now turns to the statements allegedly made by Detective Johnson. First, his statement that he would get a search warrant must be distinguished from the statements made by agents in Bumper v. North Carolina, 391 U.S. at 550. In Bumper, law enforcement officers claimed authority to search a home because they were in possession of a warrant, in effect announcing “that the occupant ha[d] no right to resist the search.” 391 U.S. at 550. The Supreme Court held that consent given after such a statement was invalid because it was coerced. Id. Here, however, assuming Johnson made the statements that he did, he did not claim that he already had a warrant; he said that he would get one. The police are entitled to seek a search warrant if they have probable cause. Giving a suspect the choice of consenting first is not, in itself, coercive behavior akin to that in Bumper. See United States v. Ivy, 165 F.3d 397, 403 (8th Cir. 1998); Mack, 796 A.2d at 970-71.