D.Ariz.: Def failed to show standing at the place where he intermittently spent nights but no showing of when

Defendant failed to show standing in the home of another. He and his girlfriend had a key to the premises where he intermittently spent the night over a fair stretch of time, but there was no showing of when he was last there and how often. “Velasco describes an intermittent overnight guest status, with no showing that he spent the night before (or even a night within the preceding week or month) the officer looked into the vehicle. Velasco has not cited to any authority establishing an intermittent overnight guest has standing to contest a search. See e.g. Minnesota v. Carter, 525 U.S. 83, 96 (1998) (Scalia, J., joined by Thomas, J., concurring) (although overnight guest status may be at “the absolute limit of what text and tradition permit” under the Fourth Amendment, it is still within the limits of the Fourth Amendment).” United States v. Velasco, 2019 U.S. Dist. LEXIS 120741 (D. Ariz. July 18, 2019).

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