CA2: Unlicensed driver of rental car rented by another had no standing in car

The court does not have to decide whether the unauthorized driver of a rental car as to the rental contract has standing, despite being loaned the car by the renter, noting differing authorities; because defendant was also an unlicensed driver he gets no standing because driving the car was unlawful. “Lyle should not have been driving any car because his license was suspended, and a rental company with knowledge of the relevant facts certainly would not have given him permission to drive its car nor allowed a renter to do so. Under these circumstances, Lyle did not have a reasonable expectation of privacy in the rental car.” United States v. Lyle, 2017 U.S. App. LEXIS 8193 (2d Cir. May 9, 2017).

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