W.D.Va.: No reasonable expectation of privacy in an unlocked vehicle parked off one’s property

Because the defendant’s truck was not on the property when the warrant for the property was issued, it wasn’t subject to the warrant. However, the truck was left unlocked and with the key in the ignition, and the court finds that shows a lack of a “reasonable expectation of privacy” in the truck. United States v. Conrad, 923 F. Supp. 2d 843 (W.D. Va. 2013).*

Defendant kept drugs in a camper on another’s property. He agrees he doesn’t have standing in the curtilage there, and he argues just in the camper, a “place of business.” There was no Fourth Amendment protection from surveillance of the camper. There was probable cause for the search in the two affidavits. A GPS device had also been placed with a warrant. United States v. Belisle, 2013 U.S. Dist. LEXIS 17805 (D. Me. February 11, 2013).*

The warrant for the cell phone was properly issued. United States v. Satchell, 2013 U.S. Dist. LEXIS 19725 (E.D. Mo. February 14, 2013).*

Pro se defendant does not argue the application of the good faith exception in the USMJ R&R, and the motion to suppress is denied. United States v. Hunter, 2013 U.S. Dist. LEXIS 19751 (D. Minn. February 14, 2013).*

Defendant’s ineffective assistance claim that defense counsel did not present some important evidence at the hearing on the motion to suppress is denied. That which wasn’t presented wouldn’t change the outcome. United States v. Harris, 2013 U.S. Dist. LEXIS 19672 (W.D. Pa. February 14, 2013).*