On remand from the Fourth Circuit, the court determines that Byrd applies and defendant had a reasonable expectation of privacy in the car he rented. As for the good faith exception, the court finds that it is bound by circuit law that said that there was no standing, despite other circuits holding that he did. Motion to suppress denied. United States v. Houston, 2019 U.S. Dist. LEXIS 1735 (W.D. N.C. Jan. 4, 2019).
Defendant’s conclusory arguments that the CI in the controlled buy wasn’t credible for issuance of a search warrant doesn’t undermine the presumption of validity of the warrant. United States v. Colon, 2019 U.S. Dist. LEXIS 581 (M.D. Pa. Jan. 3, 2019).*