California, United States of America
The following excerpt is from People v. Ybarra, 233 Cal.App.3d 1353, 285 Cal.Rptr. 200 (Cal. App. 1991):
Jeffers made it clear that mere possession of a seized item cannot be a "substitute for a factual finding that the owner of the good had a legitimate expectation of privacy in the area searched." (United States v. Salvucci, supra, 448 U.S. 83, 92, 100 S.Ct. 2547, 2553.)
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