CA2: There was no heightened expectation of privacy under Collins v. Virginia in a multi-family parking lot

Collins doesn’t provide a heightened expectation of privacy in a multi-family parking lot. “Jones does not dispute that the Dodge Magnum was inherently mobile. … We hold that the officers had probable cause to search the Dodge Magnum and that the automobile exception applies because Jones had no heightened expectation of privacy in a vehicle parked in a multi-family parking lot. The district court therefore did not err in admitting evidence recovered from the vehicle search.” United States v. Jones, 2018 U.S. App. LEXIS 16409 (2d Cir. June 19, 2018).

At a civil order of protection hearing, the trial court has no legal authority to authorize officers to enter to seize defendant’s firearms. State v. Elder, 368 N.C. 70, 773 S.E.2d 51 (2015). Similarly, there’s no end around under the statute to order defendant to surrender them. “We understand that the motivation of the trial court was simply to protect plaintiff, but the district court does not have authority under Chapter 50C sua sponte to order defendant to surrender his firearms, revoke his concealed carry permit, or to order him not to purchase or possess any firearms during the period of the no-contact order. We reverse these provisions of the no-contact order.” Russell v. Wofford, 2018 N.C. App. LEXIS 616 (June 19, 2018).