Is invasion of a defendant's personal right necessary to invoke the Fourth Amendment exclusionary rule?

Reaffirming its belief that invasion of the defendant's personal right is necessary to accord standing to invoke the Fourth Amendment exclusionary rule, the court explained in Rakas v. Illinois (1978) 439 U.S. 128, 137, 99 S.Ct. 421, 427, 58 L.Ed.2d 387: "Each time the exclusionary rule is applied it exacts a substantial social cost for the vindication of Fourth Amendment rights. Relevant and reliable evidence is kept from the trier of fact and the search for truth at trial is deflected." In Rakas the court also emphasized that the issue is not really one of standing, but, because rights secured by the Fourth Amendment are personal, whether the defendant's rights have been invaded. "[T]he question is whether the challenged search and seizure violated the Fourth Amendment rights of a criminal defendant who seeks to exclude the evidence obtained during it. That inquiry in turn [37 Cal.3d 883] requires a determination of whether the disputed search and seizure has infringed an interest of the defendant which the Fourth Amendment was designed to protect.... [T]his aspect of the

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