Defendant was an unauthorized driver of a Dollar rental car. When he was stopped, the officer called Dollar, and they wanted the car repossessed. The court finds that the car rental company cannot be a third-party consenter to a search of one of their cars sufficient to override defendant’s reasonable expectation of privacy in the car. Otherwise, any contract violation would vitiate the Fourth Amendment. United States v. Bonner, 2019 U.S. Dist. LEXIS 138205 (D. Ore. Aug. 15, 2019).
The fact Texas law may have been violated in the issuance and execution of a search warrant doesn’t matter in federal court. Here, the Fourth Amendment governs along with the good faith exception, and both were satisfied. United States v. Black, 2019 U.S. Dist. LEXIS 138161 (N.D. Tex. Aug. 15, 2019).