D.Del.: Def found on couch in morning with pillow and sheet at friend’s house had standing

“Defendant has adequately demonstrated he has standing to challenge the Search Warrant. … Defendant was found at his brother’s residence around 9:31 a.m., lying on a couch with a sheet and pillow, strongly suggesting that he was an overnight guest with a legitimate expectation of privacy. In opposition to this common-sense conclusion, the government offers nothing beyond disagreement. … On this record, the Court finds that Defendant has met his burden to show he has standing.” “[E]ven assuming (without deciding) that the Search Warrant was infirm, Defendant’s motion to suppress fails under the good faith doctrine. Therefore, the physical evidence seized pursuant to the Search Warrant will not be suppressed under the exclusionary rule.” Franks motion denied: “As already noted, the Court does not believe the apparent inaccuracies in Detective Cannon’s affidavit supporting the Search Warrant are material.” United States v. Stanford, 2020 U.S. Dist. LEXIS 212417 (D. Del. Nov. 13, 2020).*