In Rakas v. Illinois, 439 U.S. 128 (1978), the U.S. Supreme Court addressed the issue of standing to assert a Fourth Amendment violation and seek the protections of the exclusionary rule. The Court addressed the question of what standard to use in determining whether a defendant has a Fourth Amendment right of protection with respect to the place or thing searched such that the defendant could file a motion to suppress, seeking to exclude, at trial, the evidence seized. In that regard, the Court held that whether a challenged search or seizure violates the Fourth Amendment rights of a defendant seeking to invoke the exclusionary rule turns on a “determination of whether the disputed search and seizure has infringed an interest of the defendant which the Fourth Amendment was designed to protect.” Id. at 140 (emphasis added).
In State...
