The following excerpt is from U.S. v. Palacios, 959 F.2d 243 (9th Cir. 1992):
In order for a defendant to challenge the lawfulness of a search and seizure, he must first establish his standing to do so by showing that he had a "legitimate expectation of privacy" in a particular place and that this expectation was violated by the search and seizure. Rakas v. Illinois, 439 U.S. 128, 143 & n. 12 (1978). Palacios asserts that he has standing under the theory of "joint control." Appellant's Opening Brief at 29.
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