When officers came to the door with probable cause for the presence of marijuana, defendant’s shutting the door and moving about inside for up to 90 seconds created apprehension that he was destroying evidence. Also, there was at least reasonable suspicion someone else was inside for a protective sweep. United States v. Harris, 2019 U.S. Dist. LEXIS 211633 (E.D. N.C. Dec. 9, 2019).
Defendant was a passenger in the car that was searched. He claimed an ownership interest in helping make payments, paying for maintenance, and having a key. He did not, however, have his name on the title. Without more corroboration from the registered owner, the court doesn’t credit him as having standing. United States v. Johnson, 2019 U.S. Dist. LEXIS 211503 (M.D. La. Dec. 9, 2019).*