153237P.pdf   12/23/2016  United States  v.  Lemarcus Wright
   U.S. Court of Appeals Case No:  15-3237
   U.S. District Court for the Southern District of Iowa - Davenport   
   [PUBLISHED] [Colloton, Author, with Melloy and Shepherd, Circuit Judges] 
   Criminal case - Criminal law. Defendant lacked standing to challenge the 
   police officers' entry into the parking lot of an apartment complex as he 
   had no reasonable expectation of privacy in the area as he did not own or 
   live at the property; officer's action in shining a spotlight on 
   defendant's car was not a seizure; once an officer detected the smell of 
   marijuana on defendant's person, the officer had probable cause to arrest 
   him and, a fortiori, reasonable suspicion to detain him for further 
   investigation; smell of burnt marijuana and the presence of a marijuana 
   blunt in plain view in the vehicle were sufficient to justify a search for 
   drugs; seizure of a key to the car from defendant's pocket was a lawful 
   search incident to arrest.