MS: A passenger in car 20 min before stop had no standing

Defendant was in the car that was stopped for 20 minutes and admittedly had no possessory interest in the car. Therefore, he had no standing. Nowell v. State, 2018 Miss. App. LEXIS 210 (May 1, 2018).

“Williams argues the search warrant for the house at which he was sleeping was facially deficient because it failed to specify the location to be searched and the items to be seized. He also argues for the first time on appeal the warrant failed to specify his identity and his connection to the location. But the warrant contained the specific address of the house, an exhaustive list of items (including weapons, drugs, and drug paraphernalia), and it named Williams as an owner, occupant, or possessor of the property. Hence, as required under Maryland v. Garrison, 480 U.S. 79, 84 (1987), it ‘particularly describe[ed] the place to be searched and the persons or things to be seized.’ Id.” United States v. Williams, 2018 U.S. App. LEXIS 11098 (3d Cir. May 1, 2018).*

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