CA5: Interstate bus passenger had no standing against a dog sniff of the luggage compartment

An interstate bus passenger had no standing against a dog sniff of the luggage compartment of the bus. United States v. Rodriguez-Lara, 2017 U.S. App. LEXIS 3774 (5th Cir. March 2, 2017):

Rodriguez-Lara, as a passenger on a commercial bus, had the same Fourth Amendment rights as a passenger in a private vehicle. … A passenger without a property or possessory interest in a vehicle has no reasonable expectation of privacy in the vehicle itself. … Thus, Rodriguez-Lara lacked standing to challenge the initial search of the bus’s exterior luggage compartment. …

The canine officer’s subsequent sniff-search of the luggage was not a search within the meaning of the Fourth Amendment, and the canine officer’s alert to the possible presence of narcotics in the luggage constituted sufficient probable cause to permit law enforcement to search the luggage. … That probable cause permitted a warrantless search of the luggage pursuant to the automobile exception to the warrant requirement. … The district court did not err in denying Rodriguez-Lara’s motion to suppress. …