Defendant’s sister still had apparent authority to consent to search of his storage unit even though she didn’t know the access codes and she’d never been there. After inquiry by the police, it was reasonable for them to believe that she actually did have apparent authority because she had keys to the storage units. United States v. Montoya, 2016 U.S. Dist. LEXIS 152828 (D.N.M. Nov. 2, 2016).
After a series of text messages, there was probable cause to arrest defendant for possession of heroin when he arrived in the Chicago area from Austin. Officers had also listed some of the calls made by a CI. Thus, the search of his car was valid under the automobile exception. United States v. Quintana, 2016 U.S. Dist. LEXIS 148603 (N.D.Ill. Oct. 27, 2016).*