N.D.W.Va.: No REP in readily visible interior of car

There is no reasonable expectation of privacy in the interior of a car visible through the window. United States v. Swartz, 2020 U.S. Dist. LEXIS 248194 (N.D. W.Va. Dec. 11, 2020),* adopted, 2021 U.S. Dist. LEXIS 10918 (N.D. W.Va. Jan. 21, 2021).*

A homeowner’s association is not a state actor for Fourth Amendment and § 1983 purposes. Douse v. Canoe Creek Homeowner’s Ass’n, 2021 U.S. Dist. LEXIS 12377 (M.D. Fla. Jan. 4, 2021).*

After defendant’s arrest and the police left with him, his landlord’s son went in to take care of his dog, found a weapon, and turned it over to the police. This was a private search hardly instigated by the police. United States v. Perez, 2021 U.S. App. LEXIS 1969 (11th Cir. Jan. 25, 2021).

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