D.Mass.: Being jailed is not an abandonment of property in a storage unit

“The court acknowledges the government’s point that Moran did not retain a key to the storage unit once he was jailed, and that Moran had appeared perfectly amenable to the bags being placed in Alysha’s more heavily-trafficked apartment rather than in the arguably more restrictive storage unit. But at bottom, the court cannot find Moran’s actions to constitute relinquishment, abandonment, or public exposure of his belongings such that the Fourth Amendment does not attach.” Defendant, however, agreed to move the bags from the storage unit to a friend’s house where she had apparent authority to consent to their search. United States v. Moran, 2017 U.S. Dist. LEXIS 165354 (D. Mass. Oct. 5, 2017).