Defendant didn’t file a declaration under penalty of perjury contesting the facts alleged in his criminal complaint. He also fails to show even a subjective reasonable expectation of privacy in the place searched to give him standing. He abandoned his car when he saw the police: “Specifically, he does not deny that upon being approached by PRPD Agents while he was in front of a grocery store, he exited the vehicle he was inside of (i.e. the red Mazda, Model 3, Puerto Rico License plate HKH-368) and ran away, leaving the vehicle behind.” United States v. Castro-Perez, 2021 U.S. Dist. LEXIS 27032 (D.P.R. Feb. 10, 2021).
There was probable cause when the drug dog jumped unaided into defendant’s car, assuming the dog’s stiff inside was a search. United States v. Williams, 2021 U.S. App. LEXIS 4079 (5th Cir. Feb. 12, 2021).