Defendant lived in a drug dealer’s house where he rented the room in exchange for drugs. He had unfettered access to come and go. That gave him standing in his own room. The owner, however, also had unrestricted access to the whole house, and thus he had apparent authority to consent to a search of defendant’s room, too. United States v. Perdue, 2019 U.S. Dist. LEXIS 128555 (N.D. Ala. Aug. 1, 2019).
In a Title III case, the court notes the government in the application said that there was a prior search warrant but it only produced a small quantity of drugs. Therefore, more intensive measures are required, like a wiretap. United States v. Thompson, 2019 U.S. Dist. LEXIS 128763 (D. Nev. June 25, 2019).*
Another Playpen warrant sustained. United States v. Thompson, 2019 U.S. Dist. LEXIS 128685 (W.D. La. June 24, 2019).*