State v. McCammon, 250 P.3d 838

Administrative search of private property under Sedgwick County Fire Code; property included McCammon's storage unit.
Officer observed VINs through vehicle windshields during the lawful search; one VIN obstructed, third vehicle VIN not recorded.
Two of the three observed vehicles were reported stolen; McCammon charged with four counts of theft under K.S.A. 21-3701.
McCammon moved to suppress evidence; suppression motion denied; case proceeded to bench trial on stipulated facts.
Court affirmed suppression ruling and held the evidence sufficient to support all convictions despite stipulations and defense position.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was McCammon barred from challenging the search due to lack of standing?	McCammon argued lack of standing; State raised standing at suppression.	McCammon contends no standing as lessee? actually McCammon had possessory interest.	McCammon had standing to challenge the search.
Did the VIN observation/recordation constitute a Fourth Amendment search or seizure?	Observation of VINs exceeded scope of search.	No Fourth Amendment intrusion; viewing in plain view within scope.	No search or seizure; Fourth Amendment not implicated.
Was the search/recordation of VINs within the administrative warrant's scope?	Actions exceeded the warrant’s purpose to inspect fire code violations.	Analysis shows no need to assess reasonableness; threshold issue resolved.	No need for reasonableness; actions not a prohibited search or seizure.
Is there sufficient evidence to support McCammon's theft convictions on stipulated facts?	Evidence purportedly insufficient for value or knowledge.	Tutored by defense; stipulations and unsatisfactory explanations fail to negate.	Evidence sufficient; possession of stolen items and circumstances support convictions.

State v. Wickliffe, 16 Kan. App. 2d 424 (1992) (standing to challenge search discussed at district court level)
State v. Gonzalez, 32 Kan. App. 2d 590 (2004) (defendant must show proprietary/ possessory interest for suppression challenges)
State v. Jakeway, 221 Kan. 142 (1976) (standing to challenge search requires possessory interest)
State v. Sumner, 210 Kan. 802 (1972) (possession-based sufficiency considerations; identification of standing)
Horton v. California, 496 U.S. 128 (1990) (general rule on searches and seizures; connection to warranted entries)
New York v. Class, 475 U.S. 106 (1986) (VINs in plain view; no reasonable expectation of privacy in VINs)
Cardwell v. Lewis, 417 U.S. 583 (1974) (exterior visibility; no search when car exterior viewed)
State v. Grissom, 251 Kan. 851 (1992) (storage locker standing as premises; allocation of standing in rental context)
Arizona v. Hicks, 480 U.S. 321 (1987) (plain view doctrine; observational limits)
New York v. Class, 475 U.S. 106 (1986) (VIN visibility and privacy expectation)