Defendant’s arrangement with another person to pick up his package showed his control over the package, and that gave him standing. State v. Gardner, 2019 ND 122, 2019 N.D. LEXIS 130 (May 16, 2019) (quoting Treatise § 3.13).
“We conclude the warrant authorized both a search of Cody and a search of the residence, each being separately and particularly identified. … As explained above, unlike the Fleming case, the warrant application in this case clearly identified the person whose name appeared in the warrant and two separate people who were at the residence when the odor of marijuana emanated from the apartment.” State v. Muilenburg, 2019 Iowa App. LEXIS 529 (May 21, 2019).*