Court citations to blog posts are still rare enough — unless you are Sentencing Law & Policy — that I thought it was worth mentioning. From United States v. Sparks (1st Cir. Mar. 26, 2013):
The government does not dispute that Sparks, who did not own the Chrysler but was its usual driver, has standing to challenge the search here. See Jones, 132 S. Ct. at 949 n.2; cf. United States v. Gibson, — F.3d —, 2013 WL 538007, at *18-19 (11th Cir. Feb. 14, 2013). Michaud, on the other hand, seems to have had no equivalent interest in the Chrysler. See Sparks, 750 F. Supp. 2d at 387 n.4. Regardless, his suppression claim would fail for the reasons given below, so we need not consider whether he could show some other basis to challenge the search. See Orin S. Kerr, Does Fourth Amendment Standing Work Differently for Jones Trespass Searches, Traditional Katz Searches, and Long-term Katz Searches?, The Volokh Conspiracy (Feb. 14, 2012, 10:30 p.m.), https://volokh.com/2012/02/14/does-fourth-amendment-standingwork-differently-for-jones-trespass-searches-traditional-katzsearches-and-katz-long-term-expectation-of-privacy-searches/