Does a person have standing to challenge a search warrant issued by a police helicopter?

In United States v. Broadhurst, 805 F.2d 849 (9th Cir.1986), we held that "[i]t is clear that one may have a legally sufficient interest in a place other than her own house so as to extend Fourth Amendment protection from unreasonable searches and seizures in that place." Id. at 851 (citations omitted). In Broadhurst, we ruled that a person has standing to challenge an alleged search if he or she has "joint control and supervision" of the place. Id. at 852. We also concluded, however, that overflights conducted by officers of a greenhouse situated 125 yards from a two-story residence did not constitute a search requiring a warrant under the Fourth Amendment. Id. at 849-50, 856-57.