United States v. Arturo Castellanos
2013 U.S. App. LEXIS 10797
4th Cir.2013Background
- Castellanos pled guilty in the MDNC to conspiracy to distribute cocaine, challenging suppression of cocaine found in the gas tank of a Ford Explorer transported on a commercial car carrier.
- Captain Roberts conducted a warrantless, nonconsensual search of the Explorer at a Texas truck stop and found cocaine after noticing odor, apparent vehicle alterations, and tank access.
- The Explorer was listed on shipping documents with Wilmer Castenada as owner/recipient; addresses appeared false and attempts to verify them failed.
- Castellanos claimed to be purchasing the Explorer but produced no evidence of ownership; he did not show Castenada was his alias or alter ego.
- The district court denied the suppression motion after a brief bench ruling; Castellanos pled guilty with a Rule 11(a)(2) reservation to challenge the ruling on appeal; the panel has jurisdiction under 28 U.S.C. § 1291.
- The court affirmed, holding Castellanos had no reasonable, legitimate expectation of privacy in the Explorer’s gas tank at the time of the search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Castellanos had a legitimate expectation of privacy in the Explorer gas tank | Castellanos had ownership/possession or close connection to the vehicle. | Castellanos lacked ownership and any right to privacy in the Explorer; he is a third party. | Castellanos lacked a legitimate expectation of privacy in the Explorer gas tank. |
| Effect of alias and third-party shipper status on standing | Aliases do not destroy standing; he had an interest in the vehicle. | Alias and third-party shipment undermine privacy interest and standing. | Alias does not defeat standing; the record showed Castellanos had sufficient connection to the vehicle. |
| Whether the absence of a warrant and lack of consent violated the Fourth Amendment given Castellanos' standing | Without standing, Fourth Amendment protections do not apply to Castellanos. | Because Castellanos lacked privacy interest, search did not implicate Fourth Amendment rights. | Because Castellanos lacked a perceivable privacy interest, the warrantless search did not violate the Fourth Amendment under standing doctrine. |
Key Cases Cited
- Katz v. United States, 389 U.S. 347 (1967) (establishes personal privacy rights under the Fourth Amendment)
- Rakas v. Illinois, 439 U.S. 128 (1978) (standing depends on legitimate expectation of privacy, not ownership)
- Mancusi v. DeForte, 392 U.S. 364 (1968) (privacy extends beyond title ownership)
- Rawlings v. Kentucky, 448 U.S. 98 (1980) (burden on defendant to show privacy interest)
- United States v. Jacobsen, 466 U.S. 109 (1984) (sealed containers/surveillance privacy rights)
- Minnesota v. Carter, 525 U.S. 83 (1998) (standing focus on defendant's rights, not officer's state of mind)
- United States v. Givens, 733 F.2d 339 (1984) (package-delivery privacy protections)
- United States v. Crowder, 588 F.3d 929 (2009) (Seventh Circuit rule on privacy in shipped vehicle context (not adopted))