DE: Trash container at street was not on curtilage

Defendant’s trash container at the foot of his driveway awaiting pickup was not on the curtilage. Moreover, he had no reasonable expectation of privacy in it sitting there. State v. Peart, 2021 Del. Super. LEXIS 243 (Mar. 25, 2021).

Rooker-Feldman barred any claims against state officers executing a state ex parte order that were effectively appeals of state court actions. “In winnowing would-be Rooker-Feldman cases, our Circuit uses the ‘source of the injury’ standard. … If the state court judgment is the source of the injury, then Rooker-Feldman applies. Id. But ‘[i]f there is some other source of injury, such as a third party’s actions, then the plaintiff asserts an independent claim.’” Hancock v. Miller, 2021 U.S. App. LEXIS 8929 (6th Cir. Mar. 26, 2021).*