United States v. Macklin
902 F.2d 1320 (1990)
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Rule of Law:
A person lacks a legitimate expectation of privacy in the trunk of another person's vehicle and therefore lacks standing to challenge a search of that trunk under the Fourth Amendment, even if their own closed luggage is stored inside.
Facts:
- John Alvin Payne operated a cocaine trafficking conspiracy, using Tarrel Williams as a courier to transport cocaine from Los Angeles to St. Louis.
- In St. Louis, Clara Davis, an associate of Payne, would receive the cocaine from Williams for further distribution.
- On March 25, 1987, Williams flew to St. Louis with a shipment of cocaine in his luggage.
- After his luggage arrived, Williams and Davis drove in Davis's Mercedes-Benz to a hotel to retrieve it.
- Following a drug transaction at the hotel, Williams placed his luggage containing the remaining cocaine into the trunk of Davis's car.
- Shortly thereafter, Williams and Davis were arrested by law enforcement officers inside the hotel.
Procedural Posture:
- A federal grand jury indicted fifteen individuals, including Tarrel Williams, on various drug-related charges.
- Defendant Williams filed a pre-trial motion in the United States District Court to suppress cocaine found in his luggage, arguing it was seized in violation of the Fourth Amendment.
- A federal magistrate judge reviewed the motion and recommended that it be denied.
- The district court adopted the magistrate's recommendation and denied Williams' motion to suppress.
- Following a jury trial, Williams was convicted.
- Williams, along with seven other convicted co-defendants, appealed his conviction to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Does a person who places their luggage in the trunk of another person's car have a legitimate expectation of privacy in the car's trunk sufficient to challenge a search of that trunk under the Fourth Amendment?
Opinions:
Majority - Beam, Circuit Judge.
No. A person does not have a legitimate expectation of privacy in the trunk of a car that they do not own or possess. The burden is on the defendant to prove a legitimate expectation of privacy, and Fourth Amendment rights are personal, meaning they cannot be vicariously asserted. Citing Rakas v. Illinois, the court affirmed that a passenger in an automobile does not normally have a legitimate expectation of privacy in the vehicle's trunk. To establish such an expectation through a possessory interest, a defendant must typically show possession of both the vehicle and its keys. Williams presented no evidence that he had any possessory interest in Davis's Mercedes-Benz. Therefore, because he had no legitimate expectation of privacy in the trunk, he cannot challenge the legality of its search.
Analysis:
This decision reinforces the stringent standing requirements for Fourth Amendment challenges established in Rakas v. Illinois. It clarifies that merely placing personal property within a space owned by another does not confer a legitimate expectation of privacy in that space itself. This precedent makes it difficult for defendants who are passengers or temporary guests to challenge searches of vehicles or premises they do not own or control. Consequently, such a defendant's challenge is limited to the search of their personal effects (e.g., the luggage itself), not the area where those effects are stored.
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