D.Haw.: Using three people to mask defendant’s alleged ownership of a package was a lack of standing in the package

“Here, Defendant Notyce was neither the sender nor the addressee of the package. The parcel was not addressed to him or a physical location associated with him. Defendant Notyce did not retrieve the parcel from the post office box or display any other conduct that would demonstrate a privacy interest in the parcel’s contents. At minimum, Defendant Notyce used three separate people—Defendant Yanagihara, Defendant Matsuda, and an intermediary who was not charged in the indictment—to deliver the parcel to him. Accordingly, the Court finds that Defendant Notyce did not have a legitimate expectation of privacy in the parcel and therefore does not have standing to challenge its search and detention.” United States v. Notyce, 2017 U.S. Dist. LEXIS 183423 (D. Haw. Nov. 6, 2017).

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