United States v. Miguel Guevara, 448 F. App'x 453

Guevara pled guilty conditionally to possession of a stolen firearm under 18 U.S.C. § 922(j) and challenged the denial of his suppression motion for firearms, photographs, and statements.
Police executed a search warrant at a store; Guevara entered the store, was invited to talk, and was asked for name and date of birth to run a warrant check.
Guevara provided information; after no warrants were found, he orally and then in writing consented to a search of his vehicle, with the written form noting his rights and ability to withdraw consent.
Officers found a digital camera in Guevara’s vehicle, turned it on, observed photos, and learned the camera belonged to a burglarized victim, linking it to stolen firearms later found.
Guevara moved to suppress the evidence; the district court denied the motion; Guevara pled guilty conditioned on his right to appeal the suppression ruling.
On appeal, the court reviews suppression denials de novo for legal issues and for clear-error on factual findings; the case analyzes whether Guevara had standing to challenge the camera search and whether consent covered the camera search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the encounter was a seizure requiring suspicion.	Guevara argues the encounter was coercive and non-consensual.	The district court found the encounter consensual.	Encounter was consensual.
Whether Guevara's consent to search was voluntary.	Consent was involuntary due to coercive conditions.	Consent was voluntary based on procedures and awareness of rights.	Consent was voluntary.
Whether Guevara has standing to challenge the camera search.	Guevara possessed the camera and thus could challenge the search.	Guevara lacked standing because he did not lawfully possess the camera.	Guevara lacked standing.

Rakas v. Illinois, 439 U.S. 128 (1978) (standing requires legitimate expectation of privacy)
Langford, 838 F.2d 1351 (5th Cir. 1988) (no legitimate privacy interest in a stolen vehicle or contraband)
Pringle, 576 F.2d 1114 (5th Cir. 1978) (no privacy right in contraband or items one has no right to possess)
United States v. Hilton, 619 F.2d 127 (1st Cir. 1980) (no privacy interest in camera film without possessory or proprietary interest)
United States v. Botello, 991 F.2d 189 (5th Cir. 1993) (consent and privacy considerations in search cases)
Florida v. Bostick, 501 U.S. 429 (1991) (consent-based encounters and voluntary cooperation in police stops)
United States v. Gonzalez, 328 F.3d 755 (5th Cir. 2003) (standards for reviewing suppression determinations; factual findings clear-error)
United States v. U.S. Gypsum Co., 333 U.S. 364 (1948) (breakdown of factual and legal determinations in evidence review)