E.D.Tenn.: Leaving suitcase in an open grassy area is a loss of a REP in it

Defendant left his suitcase in an open grassy area, and that was a waiver any reasonable expectation of privacy in it. See United States v. Wilson, 984 F. Supp. 2d 676 (E.D. Ky. 2013) (leaving suitcase in a cemetery was a loss of any reasonable expectation of privacy). United States v. Smith, 2020 U.S. Dist. LEXIS 204154 (E.D. Tenn. Nov. 2, 2020).

“Defendant lacks standing to contest the parole officers’ search of the gun safe because he repeatedly denied ownership of it. …. Defendant cannot challenge the officers’ retrieval of a firearm and a black bag that he discarded just before his arrest because he had not yet been seized.” United States v. Crawford, 2020 U.S. App. LEXIS 34524 (9th Cir. Nov. 2, 2020).*

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