IL: Drug sale in backyard nexus to SW for house

“Granted, the drug sale did not occur inside the residence. Rather, it occurred outside the residence, in the backyard. The question, then, is whether a controlled purchase that took place in the yard of a house in which the drug seller is known to reside creates probable cause to search the interior of the house. Surprisingly, we have found no Illinois case that addresses this precise question. In the view of other jurisdictions, however, there would be probable cause to search the residence.” People v. Aquisto, 2022 IL App (4th) 200081, 2022 Ill. App. LEXIS 94 (Feb. 24, 2022).

This probation search was reasonable. Moreover, defendant had no reasonable expectation of privacy in his adult sister’s room. United States v. Slater, 2022 U.S. Dist. LEXIS 32310 (E.D.Wis. Feb. 24, 2022).

On the totality, defendant consented to a search of his person. United States v. Glenn, 2022 U.S. Dist. LEXIS 32425 (S.D.Ind. Feb. 24, 2022).*

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