The following excerpt is from United States v. Yang, 958 F.3d 851 (9th Cir. 2020):
The burden of proof is on a defendant to demonstrate that he has a reasonable expectation of privacy in the subject of the Governments warrantless search. See United States v. Caymen , 404 F.3d 1196, 1199 (9th Cir. 2005).
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