Can a person who abandoned their home without consent have standing to complain of a search and seizure?

In United States v. Jackson, 544 F.2d 407 (9th Cir. 1976), this court held that if a person has voluntarily abandoned property, he has no standing to complain of its search or seizure. The basis of the principle is that upon abandonment, the party loses a legitimate expectation of privacy in the property and thereby disclaims any concern about whether the property or its contents remain private. ⁴ The difficult question is what actions constitute an abandonment of property. In Jackson, the court stated: