OH5: Def without DL and not on rental agreement as authorized driver had no standing

Defendant never had a DL, and he was driving a rental car and wasn’t on the paperwork as an authorized driver, so the renter had no authority to let him drive. Therefore, he lacked standing. State v. Nicholson, 2017-Ohio-2825, 2017 Ohio App. LEXIS 1856 (5th Dist. May 15, 2017).

The Seventh Circuit hasn’t ruled on CSLI and the third-party doctrine. This court sensitively considers the issues on its own, noting other authorities, and finds that the third-party doctrine has to be followed. United States v. Rosario, 2017 U.S. Dist. LEXIS 73921 (N.D. Ill. May 16, 2017).*

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