Collins v. Virginia does not apply to shared parking areas which are not curtilage. “United States v. Jones, 2018 U.S. App. LEXIS 16409 (2d Cir. June 19, 2018), Jones’s vehicle was parked in a parking lot behind the multi-family building in which he lived. The court held that Jones had no legitimate expectation of privacy in the rear parking lot because it was accessible to other tenants of the building and because he did not have exclusive control of the area. 2018 U.S. App. LEXIS 16409, at *4-5. The same reasoning applies here. Shaffers was parked in a lot shared by the residents of the multi-family building.” United States v. Shaffers, 2018 U.S. Dist. LEXIS 106952 (N.D. Ill. June 27, 2018).
Hearsay is admissible at a suppression hearing as long as there is no serious challenge to its truthfulness. Moreover, the confrontation clause does not apply in suppression hearings. Squatters in a vacant apartment have no standing to challenge its search. United States v. Manning, 2018 U.S. Dist. LEXIS 107087 (E.D. Mich. June 27, 2018).