E.D.Wash.: Tribal membership confers no standing; Art. III standing isn’t 4A standing

Tribal membership confers no standing. “Article III standing is not Fourth Amendment standing, and Defendants’ argument that the Confederated Tribes [and Bands of Yakima Nation v. Yakima County, 963 F.3d 982 (9th Cir. 2020)] decision, by negative implication, means that any tribal member can validly move to suppress evidence recovered anywhere on the Yakima Nation’s land is unpersuasive.” United States v. Cloud, 2022 U.S. Dist. LEXIS 49247 (E.D.Wash. Mar. 8, 2022).

An authorized user of a car has standing, but here the evidence shows abandonment. United States v. Williams, 2022 U.S. Dist. LEXIS 49366 (W.D.Mo. Mar. 21, 2022),* R&R 2022 U.S. Dist. LEXIS 49670 (W.D.Mo. Feb. 4, 2022).*

The mission of the traffic stop was complete, but the officer went off on an unrelated investigation. Motion to suppress granted. United States v. Lewis, 2022 U.S. Dist. LEXIS 49465 (D.Nev. Mar. 21, 2022).*

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