CT: Def didn’t abandon his apt when he was in jail and rent came due

Defendant did not abandon his crime victim’s cell phone hidden in a wall when he’d been incarcerated and was evicted from his house for nonpayment of rent. The police waited until the lease had expired for nonpayment and came to the landlord to get consent. The landlord hadn’t sought legal eviction, and he let the police in five days later after the rent was due. The search was unreasonable. State v. Jacques, 2019 Conn. LEXIS 201 (July 16, 2019).

Defendant was subjected to an immigration arrest after he came out of his house and was seen in his front yard where he had no reasonable expectation of privacy. United States v. Santos-Portillo, 2019 U.S. Dist. LEXIS 115509 (E.D. N.C. May 31, 2019),* adopted, 2019 U.S. Dist. LEXIS 115456 (E.D. N.C. July 10, 2019).*