E.D.Mich.: Def was essentially and admittedly an “innocent bystander” at the place searched and had no standing

This defendant had no standing in the condo that was searched under a search warrant. He produced nothing to show that he had any connection to the property or was a guest with a connection to the premises, even an overnight guest. He was just an innocent bystander by his own admission [trying to distance himself from the drugs and cash]. He had standing in the cell phones taken off his person. There was probable cause for the search warrant, and it wasn’t stale. The seller of the drugs had a wiretap on his phone. United States v. Scott, 2018 U.S. Dist. LEXIS 80576 (E.D. Mich. May 14, 2018),* reconsideration denied, 2018 U.S. Dist. LEXIS 113218 (E.D. Mich. July 9, 2018).*

Police received a Cybertip call that defendant was sex trafficking a 16 year old girl. “Given this information on how the two met, and in light of corroboration of almost every piece of information contained within the highly detailed anonymous tip, the HPD officer could reasonably rely upon the Cybertip information.” United States v. Pelfrey, 2018 U.S. Dist. LEXIS 80530 (S.D. W.Va. May 14, 2018).*