E.D.N.C.: No REP in tent in homeless encampment that was trespassing on private property

Defendant had no reasonable expectation of privacy in his tent in a homeless encampment on someone else’s private property. That’s “wrongful presence.” He also disclaimed the tent, but standing is enough to deny relief. United States v. Tillman, 2026 U.S. Dist. LEXIS 5386 (E.D.N.C. Jan. 12, 2026).

The CI’s information recounted in the affidavit for warrant was sufficiently reliable for probable cause. “The confidential informant was an associate of the defendant who had the opportunity to observe the defendant’s illegal activities. The confidential informant told Paoletti that he or she had purchased drugs from the defendant and that the defendant was selling cocaine from his residence. The confidential informant provided a detailed description of the floor plan of the defendant’s residence, indicating that the defendant’s bedroom was on the second floor of the residence, on the ‘left hand side as one enters through the kitchen.’ Based on the confidential informant’s familiarity with the layout of the defendant’s residence, it was reasonable to infer that he or she had been inside the residence. The confidential informant also identified the specific type of firearm that the defendant had in his possession.” State v. Velazquez, 2026 Conn. App. LEXIS 17 (Jan. 13, 2026).* [Not even close.]