Tenth Circuit US v. Ruiz 10-333

Decision here,

   There really isn't anything too surprising in this case.

   Ruiz rented space in an airplane hangar to store his plane.  He was acting suspicious, so the airport employees called the police.  The police ran a dog on the outside of the plane, which detected the odor of drugs, and then they got a warrant for the plane.  They found drugs.

   Later, the police were called to a residence that Ruiz had formerly rented.  He had abandoned the property, and left a note informing his landlords that he was abandoning the property (he also asked them to hang on to his stuff until he could collect it).  The landlords had found some suspicious property left behind, and they called the police.  The police found drugs.

   Ruiz moved to suppress the drugs found in both cases, saying that he had a reasonable expectation of privacy in the hangar and in the residence.  The court held that Ruiz did not have a reasonable expectation of privacy in the hangar, because it was space that he shared with other rental customers (and which he did not have 24 hour access to, although the manager who consented to the search did).  The court also held that Ruiz had abandoned the rental property, and no longer had a reasonable expectation of privacy there (his former landlords did have standing, but they also consented to the search).  And so the judgement of the lower courts was affirmed.

   This one seemed pretty obvious to me. I'm surprised that the case made it as far up as the tenth circuit.