In a stipulated evidence suppression hearing, defendant did not preserve the issue he presents for appeal. Going to the merits anyway, defendant claimed that his rented room in what was, for all appearances, a single family dwelling was reasonable. The defense presented a police witness with prior knowledge of the premises who wasn’t in on this search who was aware of the arrangement, but nothing put the officers executing the warrant on notice that there was a separate unit inside: one mailbox, one entrance, no number on the door. There was a padlock on the door, but it was partially open at the time, and the fact the door could be locked is only a factor to consider. State v. Marsh, 2019 Minn. App. LEXIS 229 (June 24, 2019).
Defendant passenger in a car had no standing to challenge the search. The search was valid in any event because it was prolonged with reasonable suspicion. United States v. Lancon, 2019 U.S. Dist. LEXIS 103562 (S.D. Ala. June 20, 2019).*