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131231P.pdf   03/11/2014  United States  v.  John Douglas
   U.S. Court of Appeals Case No:  13-1231
   U.S. District Court for the District of Minnesota - St. Paul   
   [PUBLISHED] [Riley, Author, with Colloton and Kelly, Circuit Judges] 
   Criminal case - Criminal law. District court did not err in denying 
   defendant's motion to suppress a shotgun found hidden in a trash bag in an 
   abandoned refrigerator in an open field on his relative's vacant, rural 
   property; under the circumstances, defendant did not have an objectively 
   reasonable expectation of privacy; further, defendant repeatedly disavowed 
   any ownership or posessory interest in the bag or the shotgun and could 
   not claim the bag was searched and the gun seized in violation of his 
   rights.