D.Mass.: No REP in video surveillance in an apartment building hallway that covered def’s door

“Defendants may have held a subjective expectation that activity in and around the doorway of the apartment would remain private but such an expectation was not objectively reasonable because their activity took place in a common area exposed to the public. Thus, Bean-Bousseau and Parsons do not have standing under the Fourth Amendment to suppress the evidence obtained from the apartment hallway camera. [¶[ A similar analysis applies to the challenged surveillance of the parking lot and building exterior at One Mansfield.” United States v. Bean-Bousseau, 2023 U.S. Dist. LEXIS 871 (D. Mass. Jan. 4, 2023).

The initial encounter was consensual and ripened to reasonable suspicion for detention. United States v. Anderson, 2023 U.S. App. LEXIS 113 (4th Cir. Jan. 4, 2023).*

An argument in a car with screaming in a Target parking lot caused employees to call the police. Defendant wasn’t seized when approached by the police, even when he was told to “hop out of the car.” His actions led the officer to reasonably suspect he was hiding a gun. United States v. Blount, 2023 U.S. App. LEXIS 108 (4th Cir. Jan. 4, 2023).*

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