Analyzing bailments under PR law and First Circuit and SCOTUS cases (particularly Rawlings), defendant’s precipitous five second holding of a bag handed off to him wasn’t sufficient to create a bailment or give him standing in the bag. United States v. Sierra-Ayala, 2019 U.S. Dist. LEXIS 129887 (D.P.R. Aug. 2, 2019).
An alcove where trash bins were 30 yards from defendant’s house wasn’t part of the curtilage. Neighbors apparently used it too, so there is no reasonable expectation of privacy there. United States v. Suris, 2019 U.S. Dist. LEXIS 129782 (C.D. Cal. Aug. 3, 2019).*