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Valle v. State

The defendant lacked standing to challenge the search of a vehicle in which he was a passenger because he had no reasonable expectation of privacy in a garbage bag he placed in the trunk.

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Following a bench trial, the court found Eric Valle guilty of trafficking in cocaine and trafficking in marijuana. In four enumerations of error, Valle challenges the trial court’s denial of his motion to suppress. For reasons that follow, we affirm. In reviewing a trial court’s ruling on a motion to suppress, we are guided by three principles.1 First, the trial court acts as fact-finder, and we will affirm that court’s resolution of conflicts in the evidence if there is any evidence to support it.2 Second, we defer to “the trial court’s decision as to questions of fact and credibility unless they are clearly erroneous.”3 And, in reaching our decision, we construe the evidence in a light favorable to upholding the lower court’s judgment.4

Viewed in this manner, the record reveals that on September 8, 2004, police were conducting surveillance on Eric Valle, who was suspected of involvement in cocaine trafficking. While undercover Agent Allen Martin was watching Valle’s home, Martin saw Valle leave the residence, carrying a white, plastic trash bag that appeared heavy. According to Martin, he “could see the indentation of what appeared to be . . . either the corner of a kilo . . . of cocaine or the corner of a bale of marijuana.” Valle placed the bag in the hatchback of a Ford Escort and sat in the passenger seat of the vehicle. Another man, subsequently identified as Victor Gilles, drove the car from the house.

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