Assuming the search of defendant’s stuff in the house of another was not valid as a parole search, defendant doesn’t even really attempt to show guest standing under Olson. United States v. Shelton, 2019 U.S. Dist. LEXIS 71028 (M.D. Tenn. Apr. 26, 2019):
Albeit a close call, the Court finds that Defendant has not met his burden to establish standing. The exhaustive list of questions that the Court discusses above are one indication that Defendant has failed to provide enough evidence to the Court to demonstrate standing by a preponderance of the evidence. Moreover, the evidence Defendant has in fact submitted to the Court, discussed above, falls short of establishing an expectation of privacy in 3565 Chesapeake Drive. The evidence amounts to: (a) terse, out-of-court statements from Defendant to the effect that he had moved out of 317 Tillman and into 3565 Chesapeake; (b) terse, out-of-court statements from one other person (with an unspecified basis of knowledge) that Defendant was “staying” at 3565 Chesapeake and had a relationship a woman who perhaps resided there; (c) testimony that Defendant possessed a key to a room inside 3565 Chesapeake Drive in which officer found a photograph of Defendant and items suggest a possible connection to drug-trafficking operations; (d) and testimony regarding the discovery of items at 317 Tillman suggesting that Defendant possibly still could be staying overnight there.