MI: Passenger in car has standing to challenge search of his own backpack (overruling LaBelle)

While a passenger in a car normally doesn’t have standing in the contents of a car, he does in his own backpack that he was carrying when he got into the car. The driver couldn’t consent to a search of the passenger’s backpack. People v. Mead, 2019 Mich. LEXIS 635 (Apr. 23, 2019), overuling People v. LaBelle, 478 Mich, 891, 732 N.W.2d 114 (2007).

The first time CI’s information was well enough corroborated that there was probable cause on the totality. Commonwealth v. Harlan, 2019 PA Super 124 (Apr. 23, 2019).*