CA11: Crew of foreign registered ship boarded in international waters has no 4A standing

Defendant had no Fourth Amendment standing when he was a foreign national on a ship of a foreign country that drew the Coast Guard’s attention south of the Cayman Islands. The Coast Guard finally boarded the ship after the country it was registered to gave permission. 140 bales of cocaine were found. Due to water taken on during a storm after the offloading, the ship sank. Seven were taken into custody. United States v. Hurtado, 2023 U.S. App. LEXIS 33816 (11th Cir. Dec. 20, 2023).

A Santa Muerte shrine (for the patron saint of drug traffickers) found during execution of a search warrant was admissible at trial with expert testimony. United States v. Martinez, 2023 U.S. App. LEXIS 33722 (10th Cir. Dec. 20, 2023).*

The traffic stop was concluded by a warning, but the officer asked for consent. Defendant said he was on probation so the officer was going to get to search anyway. The officer asked for confirmation of consent, and it was yes. Both theories support the search. State v. Michael, 2023 N.C. App. LEXIS 840 (Dec. 19, 2023).*

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