standing, that is a “reasonable expectation of privacy” in the place that was searched.
Brackets v. Illinois
, 439 U.S. 128, 143 (1978). Ownership of a vehicle is not determinative of standing tochallenge the constitutionality of the search.
Rawlings v. Kentucky
, 448 U.S. 98, 104-106(1980);
United States v. Ramapuram
, 632 F. 2d 1149, 1155 (4 Cir. 1980). A warrant must
specify the places to be searched and things to be seized with sufficient particularity that theofficer with the warrant can with reasonable effort ascertain and identify the place intended.
Steele v. United States
, 467 U.S. 498, 503 (1925). See also
Stanford v. Texas
, 379 U.S. 476, 148-85 (1985) (describing the history, purpose and particularity requirement).Here Defendant Cornell has standing because he was a resident of 2809 Keeler Street, theresidence searched on June 27, 2007, and was the renter of the van stopped by police on April 24,2010.The affidavit in support of the search warrant of the 2809 Keeler Street is patentlyinsufficient to establish probable cause Even a cursory review of the warrant attached as ExhibitA hereto reveals that it contains no reliable information to establish probable cause. For example:a.The affiant stated the following: “a confidential source [said] that they havewitnessed persons from 2809 Keeler St partaking in drug activity outside of their business.” The affidavit provides no information about the reliability of thissource. It does not identify these persons. The affidavit provides no link betweenthe residence and the drug activity; since Keeler street is a residence and theaffidavit indicates that the drug activity occurred outside the confidential source’s business there is no explanation of why there is a connection to residence.
United States v. Lalor
, 996 F.2d 1578 (4 Cir. 1993).In addition, there is no information
about the temporal relationship of the receipt of the information to the date on
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