What is the test for abandonment of property under the Fourth Amendment?

Persons "who voluntarily abandon property lack standing to complain of its search or seizure." United States v. Nordling, 804 F.2d 1466, 1469 (9th Cir.1986). Furukawa relinquished possession of the bags to the airline and then denied ownership of them. Relinquishment of possession and denial of ownership is sufficient to establish abandonment for Fourth Amendment purposes, even when, as in this case, the officers earlier saw the defendant in possession of the property. United States v. Veatch, 674 F.2d 1217, 1221 (9th Cir.1991).