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Byrd v. United States
United States Supreme Court
138 S. Ct. 1518 (2018)
Facts
Terrence Byrd (defendant) was the driver of a rental car but was not listed on the rental agreement. Police stopped the car Byrd while was driving and searched it, finding marijuana in the trunk. Byrd was arrested and filed a motion to suppress the evidence found in the trunk of the rental car on the theory that the search had violated his rights under the Fourth Amendment to the United States Constitution. At the suppression hearing, the United States (plaintiff) asserted that Byrd was not in lawful possession of the vehicle at the time of the search, but this fact was not determined by the trial court. The trial court denied Byrd’s motion to suppress on the grounds that Byrd lacked standing to object to the search. Byrd entered a conditional plea and reserved the right to appeal the trial court’s denial of his motion to suppress. The court of appeals affirmed the trial court’s ruling but noted that there was a split among the circuit courts of appeal over whether the driver of a rental vehicle who is not named on the rental agreement has a Fourth Amendment expectation of privacy in the vehicle. The United States Supreme Court granted certiorari to resolve the circuit split.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
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