OH7: Visitor to hotel room with no key or shown association to room had no standing

Defendant was a visitor to a hotel room and he had no standing to challenge its search. He had no key to the room and no luggage or other belongings, and he couldn’t show he was a guest of either the hotel or the renter of the room. State v. Smith, 2021-Ohio-3330, 2021 Ohio App. LEXIS 3245 (7th Dist. Sept. 15, 2021).

There was probable cause for the search of defendant’s vehicle, and it would have been searched by inventory anyway. United States v. King, 2021 U.S. Dist. LEXIS 180711 (E.D.Mich. Sept. 22, 2021).*

Probable cause was shown for obtaining defendant’s CSLI, and, even if it didn’t, the good faith exception applies. United States v. Villar, 2021 U.S. Dist. LEXIS 181155 (S.D.N.Y. Sept. 22, 2021).*

Defendant’s Franks challenge fails. More than mere accusations are required to get a hearing; no offer of proof, no affidavits. United States v. Zambrano, 2021 U.S. Dist. LEXIS 181287 (N.D.Ill. Sept. 22, 2021).*

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