Lifting the tarp off a parked car was reasonable as a protective sweep. The officer did not search the car – he only looked in it to make sure no one was hiding there. Defendant’s wife permitted entry into the house to look for defendant, and clothing matching the description of what the defendant wore at the time of the crime was seen and seized then. United States v. Blatchford, 2017 U.S. Dist. LEXIS 87932 (D. Ariz. June 8, 2017).
“Defendant abandoned any reasonable expectation of privacy in his BMW, which was parked at a restaurant as he committed the offense of entering auto because, when confronted by Off. Kuo, he fled the scene on foot — leaving the BMW running with the key in the ignition, no occupants and the door open.” He also claimed that the car had been carjacked earlier that day. United States v. Elkins, 2017 U.S. Dist. LEXIS 86637 (N.D. Ga. April 13, 2017),* adopted, 2017 U.S. Dist. LEXIS 86542 (N.D. Ga. June 6, 2017).*