A temporary guest on the property had no standing in the curtilage. Even so, the officer’s merely looking in his vehicle and seeing Sudafed in plain view wasn’t a Fourth Amendment violation. “It is undisputed that Carr had been inside 463 Sunflower Lane for only a few minutes; he did not know the other people there; he does not own the home; and he does not know who does. He was not a guest who ‘typif[ies] those who may claim the protection of the Fourth Amendment.'” Carr v. Hoover, 2020 U.S. App. LEXIS 37668 (5th Cir. Dec. 2, 2020).
The district court erred in granting summary judgment for the officers in an excessive force case. “Viewing the facts in the light most favorable to the Estate, including the actions of the police officers that may have recklessly escalated the situation, a reasonable jury could find that Officers Girdner and Vick violated Dominic’s Fourth Amendment right to be free from unreasonable seizure.” Bond v. City of Tahlequah, 2020 U.S. App. LEXIS 37488 (10th Cir. Dec. 1, 2020).*