Cal.4: No REP from images caught by streetlight camera

Defendant had no reasonable expectation of privacy from images taken on a street light camera where he parked his vehicle. Carpenter just doesn’t apply. Moreover, a store surveillance camera had him there, too. People v. Cartwright, 2024 Cal. App. LEXIS 40 (4th Dist. Jan. 25, 2024).

“At bottom, this evidence established a nexus between the Residence and the crimes under investigation, and neither the lapse of time between controlled purchases, nor the lapse of time between the last controlled purchase and obtaining the search warrant, rendered this nexus stale.” Even if not, the good faith exception applies. United States v. Gillard, 2024 U.S. Dist. LEXIS 12324 (E.D. Pa. Jan. 24, 2024).*

Testimony three times that defendant insisted on a search warrant was harmless error if anything.
“In this case, although the State referred to the Defendant’s insistence upon a search warrant on three occasions, it did not try to convince the jury to attribute any particular significance to the statement. More importantly, the State’s proof of the Defendant’s guilt was overwhelming.” State v. Sullivan, 2024 Tenn. Crim. App. LEXIS 20 (Jan. 24, 2024).*

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