Byrd doesn’t give the passenger any more standing than he already didn’t have. United States v. James, 2019 U.S. App. LEXIS 15531 (5th Cir. May 24, 2019).
“Under our precedent that applied to the stop at issue, the officers’ use of a dog sniff was reasonable both because Leon consented to a search and because the extension of the stop was de minimis in light of his consent.” United States v. Leon, 2019 U.S. App. LEXIS 15546 (8th Cir. May 24, 2019).*