United States v. Aiken, No. 17-1036 (1st Cir. 2017)
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The First Circuit reversed the district court’s judgment ruling that Defendant had a reasonable expectation of privacy under the Fourth Amendment in the motel room where he was at the time of a police search of the premises, holding that Defendant, a guest of a guest in the motel room, did not have a reasonable expectation of privacy in the motel room.
Defendant was charged with possession with intent to distribute a mixture or substance containing cocaine based and aiding and abetting such conduct. Defendant moved to suppress the evidence seized as a result of the search of the motel room where he had been staying. The district court ruled that the search violated the Fourth Amendment and suppressed the evidence. The First Circuit reversed and remanded, holding (1) the district court properly found that Defendant was the guest of a guest; but (2) Defendant failed to demonstrate an objectively reasonable expectation of privacy in the motel room.
The court issued a subsequent related opinion or order on January 2, 2018.
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