In United States v. Jones, the Circuit affirmed the district court’s refusal to suppress evidence seized during a warrantless search of a car parked in the common parking lot of a multi-family building. The Circuit held Jones had no legitimate expectation of privacy in his car because it was parked in a driveway shared by tenants of two multi-family homes, not within the curtilage of his private home, and he did not have exclusive control over the driveway. Op. at 13-15.
In United States v. Sawyer, the Circuit remanded the case for the second time, this time for resentencing in front of a new district judge. The Circuit previously had vacated as substantively unreasonable a 360-month sentence for the offenses of producing and receiving child pornography. In that opinion, the Circuit held that the “30-year sentence would have been appropriate for ‘extreme and heinous criminal behavior’ and the …