W.D.La.: Use of key fob to find def’s car in Walmart parking lot wasn’t unreasonable search

Using defendant’s key fob to find his car in a Walmart parking lot was not an unreasonable search because there was no reasonable expectation of privacy in which car was his, following United States v. Cowan, 674 F.3d 947 (8th Cir. 2012). United States v. Artigas, 2018 U.S. Dist. LEXIS 42994 (W.D. La. Feb. 27, 2018).

“The information provided in the affidavit suggests more than a fair probability that evidence of drug crimes will be found at that particular place. These five sources, taken as a whole, undoubtedly demonstrate a concrete nexus between the evidence sought (drugs, guns, money, and other drug-crime-related paraphernalia) and the Fenton Avenue address. Accordingly, the Search Warrant is supported by probable cause.” And, the good faith exception applies. United States v. Grimes, 2018 U.S. Dist. LEXIS 42402 (S.D. Ohio Mar. 15, 2018).*

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