MN: Stairway of a duplex is a common area, not curtilage

Defendant had no reasonable expectation of privacy in the stairwell of his duplex because it was a common area, not curtilage. Shell casings seen there were in plain view. State v. Milton, 821 N.W.2d 789 (Minn. 2012).

Defendant had no standing to challenge the search of the place and cell phones found there because he had no legitimate connection to it. He did, however, have standing to contest the search of four bags he left there when the police were on notice that they were his bags such that the owner of the place could not consent to them. United States v. Hollister, 2012 U.S. Dist. LEXIS 134091 (D. Minn. July 23, 2012).*

When officers knocked on the door, they were told “this is a house of peace” and were invited in. Once inside, she consented to a search of the premises. United States v. Sroufe, 2012 U.S. Dist. LEXIS 134619 (N.D. Ga. July 16, 2012).*