While defendant was in a place where he had no standing, he still had a reasonable expectation of privacy in his cell phone from a warrantless search. State v. Barajas, 817 N.W.2d 204 (Minn. App. 2012):

This constitutional protection extends to items "thus closed against inspection, wherever they may be." Ex parte Jackson, 96 U.S. 727, 733, 24 L. Ed. 877 (1878) (emphasis added) (recognizing Fourth Amendment protection of sealed letters or packages in the mail); see also United States v. Van Leeuwen, 397 U.S. 249, 251, 90 S. Ct. 1029, 1031-32, 25 L. Ed. 2d 282 (1970) (reaffirming this principle). Indeed, an individual does not necessarily relinquish the constitutional protection afforded to the concealed contents of a closed container by taking the container to a location in which the individual lacks a reasonable expectation of privacy. See Bond, 529 U.S. at 338-39, 120 S. Ct. at 1465 (holding that defendant retained some privacy interest in contents of bag brought onto public bus); United States v. Owens, 782 F.2d 146, 150 (10th Cir. 1986) (holding that holdover guest's luggage left in motel room retained Fourth Amendment protection even though motel had legal right to forcibly evict holdover guest); State v. Mooney, 218 Conn. 85, 588 A.2d 145, 161 (Conn. 1991) (holding that defendant retained reasonable expectation of privacy in contents of duffle bag and cardboard box located under highway bridge where he was living). Our careful research, however, has identified no published decisions in Minnesota articulating whether a cellular telephone may be treated as a closed container, the digital contents of which are protected from unreasonable government searches. The facts and circumstances here require us to address this matter of first impression.

The origin of the protection afforded to closed containers is Ex parte Jackson, in which the United States Supreme Court held that the contents of sealed letters or packages in the mail cannot be searched by government agents without a warrant. 96 U.S. at 733. Since then, the United States Supreme Court has explained that the general rule protecting the contents of closed containers applies broadly to all types of containers because "a constitutional distinction between 'worthy' and 'unworthy' containers would be improper." Ross, 456 U.S. at 822, 102 S. Ct. at 2171. As the Ross court observed, "a traveler who carries a toothbrush and a few articles of clothing in a paper bag or knotted scarf [may] claim an equal right to conceal his possessions from official inspection as the sophisticated executive with the locked attaché case." Id. Similarly, person's privacy interest in the contents of a cellular telephone is not diminished by virtue of those contents' digital format. See Katz, 389 U.S. at 352-53, 88 S.Ct. at 512 (rejecting claim that Fourth Amendment protects only tangible property);1 Wayne R. LaFave, Search and Seizure: A Treatise on the Fourth Amendment § 2.6(f) (4th ed. 2004) (observing that the Katz holding suggests that digital information may be protected from unreasonable searches). A cellular telephone that conceals its contents is consistent with the broad definition of constitutionally protected containers described in Ross.

Moreover, rapid advancements in cellular-telephone technology have broadened the capabilities of telephones beyond communication to include the creation and storage of private data that the owner does not intend for others to view. Cellular telephones are capable of storing substantial amounts of private data, including address books and photographs. Smith, 920 N.E.2d at 954-55; see also State v. Ferguson, 804 N.W.2d 586, 591-92 (Minn. 2011) (recognizing contacts list from cellular telephone as evidence). Here, the record clearly establishes that Barajas's cellular telephone is capable of taking and storing digital photographs. For the purpose of determining the constitutionality of a police search, we cannot identify a meaningful distinction between the digital photographs stored in Barajas's cellular telephone and the personal items stored in the paper bag contemplated by the United States Supreme Court in Ross.

We are mindful that, because cellular telephones are capable of sharing information with the public or third parties, the contents of a cellular telephone are not always truly concealed. See Gail, 713 N.W.2d at 860 (concluding that defendant lacked reasonable expectation of privacy in cellular telephone call history because defendant sublet the cellular telephone and the records were held by the telephone service provider and exposed via the "Caller ID" function on the cellular telephone of defendant's call recipient); Smith, 920 N.E.2d at 954 (observing that some cellular telephones can transmit or receive text messages and other data and access the Internet). And the contents of closed containers are not shielded from warrantless intrusion if the container's outward appearance betrays its contents. Sanders, 442 U.S. at 764 n.13, 99 S. Ct. at 2593 n.13. But these circumstances are not before us.

Defendant was running in a high crime area wearing baggy jeans, apparently not doing it for the exercise. This justified a stop. State v. Jimenez, 2012 Ohio 3318, 2012 Ohio App. LEXIS 2917 (12th Dist. July 23, 2012).*

The stop was justified for a traffic offense, and the officer asked about the marijuana he could smell. That did not prolong the stop. Parker v. State, 317 Ga. App. 93, 730 S.E.2d 717 (2012).*

Defendant’s running a red light was cause for a stop. While the officer was admittedly confused about a detail, he was found otherwise credible, and that’s binding. State v. Bostock, 2012 Ohio 3324, 2012 Ohio App. LEXIS 2918 (4th Dist. July 19, 2012).*

The fact there was no specific reasonable suspicion as to the driver didn’t matter if there was as to co-conspirators in the car. United States v. Zamora-Lopez, 685 F.3d 787 (8th Cir. 2012):

Zamora-Lopez argues the deputies lacked reasonable suspicion that the unknown driver of the Jeep was involved in Memo's narcotics trafficking operations. This argument relies on a too-narrow conception of reasonable suspicion and fails to consider the totality of the information available to the deputies. See Stewart, 631 F.3d at 457. The supplier earlier described to law enforcement a very specific pattern of long-standing conduct that nearly always involved three people—the supplier, Memo, and an unknown driver. Memo and his driver sometimes arrived in a silver SUV. Memo's driver frequently stayed in the area to pick up Memo following the drug transaction. The deputies' surveillance observations during the controlled buy confirmed the supplier's account in virtually every detail. Cf. Illinois v. Gates, 462 U.S. 213, 241-46, 103 S. Ct. 2317, 76 L. Ed. 2d 527 (1983) (concluding probable cause existed to issue a search warrant where an anonymous informant's tip was corroborated by law enforcement officers' independent investigations).

The deputies believed Memo was an experienced and high-volume drug trafficker. Such an individual might be expected to rely on trusted confederates to drive him to and from his drug transactions. While Memo might have used unknown and innocent drivers, it was reasonable for the deputies to suspect the unidentified driver was knowingly involved in Memo's drug trafficking activities. Thus, Zamora-Lopez's Fourth Amendment rights were not violated, and the district court's admission of the evidence resulting from the traffic stop was proper.

Officers received a tip that defendant, a pharmacist, had child pornography on a computer. They investigated as best they could and found no support for it. A year later, officers came to his house and, after knocking for several minutes did not bring him to the door, they supposedly feared that he could be ill or worse. Their knocking woke his next door neighbor. Officers entered through a partially open and unlocked sliding glass door and heard moaning. With guns drawn they found defendant nude on an air mattress and unarmed. He said he would talk to them after he got dressed and he’d meet them outside. They went back outside, and he came outside. They never looked at or touched anything. By this time, a child pornography investigator was at the house. Defendant agreed to an entry, and it was admittedly by consent. The court found the second entry was attenuated from the initial entry, valid or not. This was a classic knock-and-talk. United States v. Smith, 688 F.3d 730 (11th Cir. 2012):

In undertaking this [Herring exclusionary rule] analysis, "[w]e are obliged to determine whether the consent was 'sufficiently an act of free will to purge the primary taint of the unlawful invasion,' or, alternatively, whether the causal connection had 'become so attenuated as to dissipate the taint.'" Delancy, 502 F.3d at 1309 (quoting Wong Sun, 371 U.S. at 486-87, 83 S. Ct. at 416-17). This inquiry requires that we review carefully the facts and circumstances of each case. Although no single factor is dispositive, we have identified previously three helpful factors in framing the analysis: (1) the temporal proximity of the illegal act and the subsequent consent, (2) the intervening circumstances and (3) the purpose and flagrancy of the officers' misconduct. Id. These factors "are not meant to be exhaustive." Id. The underlying question "involves a pragmatic evaluation of the extent to which the illegal police conduct caused the defendant's response." Id. at 1310 (internal quotation marks omitted).

We turn first to the time that elapsed between the officers' entry and Mr. Smith's consent. Our case law reflects the commonsense principle that the more time that has elapsed between the illegal act and the defendant's consent, the more likely it is that the defendant's consent was untainted. Id. ...

ABAJ.com: Patriots Debate: The Data Question: Should the Third-Party Records Doctrine Be Revisited? by Orin Kerr and Greg Nojeim:

Introduction

If a suspected thief has left written records of his crime in a friend’s desk, can the police simply subpoena the friend for the records in the desk or should that be treated as a search of the suspect’s property?

That question is at the heart of the “third-party records doctrine,” which has provided guidelines for criminal investigations since the late 1970s. In essence, the doctrine holds that information lawfully held by many third parties is treated differently from information held by the suspect himself. It can be obtained by subpoenaing the third party, by securing the third party’s consent or by any other means of legal discovery; the suspect has no role in the matter, and no search warrant is required.