NY4: No standing in search of a common basement storage area “not associated with his apartment”

Defendant showed no standing to contest a search of a common basement storage area, “not associated with his apartment.” People v. Ocasio, 2023 NY Slip Op 06623, 2023 N.Y. App. Div. LEXIS 6727 (4th Dept. Dec. 22, 2023).

Even if defendant’s apartment was entered unlawfully, officers were getting a search warrant and the independent source doctrine applies. United States v. Jefferson, 2023 U.S. App. LEXIS 33953 (5th Cir. Dec. 21, 2023).*

There were four CIs and controlled buys. While CIs 1,2,4 were of unknown reliability, they cross-corroborated each other. Recording the controlled buys in his house violated no rights when he permitted the CI in. United States v. Graham, 2023 U.S. Dist. LEXIS 227737 (D. Neb. Nov. 6, 2023).*

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