State v. Jones, 2016 Ohio 7831

Appellant Rickey D. Jones was indicted on trafficking and possession of marijuana counts and permitting drug abuse based on a drug investigation of 6223 Zoellners Place in Hamilton, Ohio.
Detective Whitehouse's affidavit for a search warrant named resident Aris Trammell, recited a trash pull indicating trafficking, and stated Jones's vehicle had been at the residence, Jones had been seen entering the residence, and had spoken with drivers in the driveway.
A warrant was issued; the search recovered over 5,000 grams of marijuana, a firearm, scales, bagging material, and multiple cellphones.
Jones moved to suppress the seized evidence; the trial court denied the motion, finding the affidavit established probable cause.
Jones pleaded no contest to trafficking and possession, was sentenced to 18 months, and appealed the denial of his suppression motion, arguing the search was unlawful.
The appellate court affirmed, holding Jones lacked standing to challenge the search because he failed to prove a legitimate expectation of privacy in Trammell’s home.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jones had standing to challenge the search of Trammell's home	State: Jones failed to show a privacy interest; burden on defendant to prove expectation of privacy	Jones: Sought to suppress evidence seized at Trammell’s residence as violative of Fourth Amendment rights	Court: Jones lacked standing; he presented no evidence of residency, overnight guest status, or other privacy interest, so suppression denied
Whether affidavit supported probable cause for warrant (decision unnecessary after standing ruling)	State: Affidavit established probable cause via trash pull, observed activity, and Jones's ties to residence	Jones: Challenged the search warrant/evidence seized (but court resolved case on standing)	Court: Did not reach the merits of probable cause because standing alone disposed of the suppression claim

Rakas v. Illinois, 439 U.S. 128 (1978) (Fourth Amendment rights are personal and cannot be vicariously asserted)
Minnesota v. Carter, 525 U.S. 83 (1998) (limited circumstances where nonresident may have expectation of privacy, e.g., overnight guest)
Rawlings v. Kentucky, 448 U.S. 98 (1980) (defendant bears burden to prove a legitimate expectation of privacy to challenge a search)
State v. Coleman, 45 Ohio St.3d 298 (1989) (one cannot claim Fourth Amendment protection for searches of another's property absent personal privacy interest)
State v. Dennis, 79 Ohio St.3d 421 (1997) (defendant must prove an expectation of privacy to challenge a search)
State v. Williams, 73 Ohio St.3d 153 (1995) (same: burden on defendant to establish standing to contest warrant-based search)