E.D.Mich.: Def lacked standing in a hotel room he occasionally frequented but hadn’t been in for 17 days

Officers conducted a raid on hotel rooms for human trafficking evidence. Defendant’s name on a receipt was found in the room from 17 days earlier. He admits that he wasn’t a guest the night before or regularly before the raid. He lacks standing to challenge the search. United States v. Bell, 2019 U.S. Dist. LEXIS 138578 (E.D. Mich. Aug. 16, 2019).

Ohio’s drug overdose immunity statute protects defendant from what he had on him when he was treated for an overdose, including immediately thereafter in transport to the jail and being searched there. That which was discovered by a search before the overdose isn’t immune. State v. Miller, 2019-Ohio-3294, 2019 Ohio App. LEXIS 3378 (2d Dist. Aug. 16, 2019).*

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