State v. Wescott

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE STATE OF DELAWARE ) ) v. ) ) I.D. Nos. 2507007410 GARRON D. WESCOTT, ) 2507007277 ) Defendant. ) Submitted: August 24, 2026 Decided: September 18, 2026 ORDER Upon Defendant’s Motion to Suppress DENIED 1. Defendant Garron D. Wescott (“Defendant”) has moved to suppress the contents of a United States Postal Service (“USPS”) parcel that a postal inspector removed from the mail stream for a canine sniff, together with all evidence derived from that parcel, on the ground that the parcel was seized without a warrant and without reasonable articulable suspicion, in violation of the Fourth and Fourteenth Amendments to the United States Constitution and Article I, § 6 of the Delaware Constitution. Because Defendant has not established a legitimate expectation of privacy or a possessory interest in the parcel, and because, in any event, the parcel’s brief detention was supported by reasonable articulable suspicion, Defendant’s motion is DENIED. 2. The facts are as they appear to the Court following an evidentiary hearing held on August 24, 2026. On June 23, 2025, Detective Tillman of the Delaware State Police contacted the United States Postal Inspection Service and spoke with Robert DiDomenico (“DiDomenico”), who has served with the Inspection Service since 2012 and has intercepted between fifty and one hundred parcels that proved to contain controlled substances. 1 Detective Tillman advised that the Delaware State 0F Police had an ongoing narcotics investigation of Defendant and that investigators had received information that a shipment of cocaine would arrive by mail for Defendant, at his residence in Milford, Delaware (the “Milford Address”), within approximately three to four days. 3. DiDomenico reviewed USPS records for the Milford Address and determined that the address had previously received parcels sent from the greater Los Angeles, California area, which DiDomenico knows from training and experience to be a source location for narcotics shipped through the mail. 2 1F DiDomenico did not observe any parcel addressed to Defendant arrive within the three-to-four-day window that Detective Tillman had described. On or about July 10, 2025, however, DiDomenico determined that the internet protocol (“IP”) address that was tracking a parcel destined for the Milford Address was also tracking a second parcel, then in transit, addressed to Aubree Gibbs at a residence in Lincoln, Delaware (the “Parcel”). 3 2F 4. The Parcel had been mailed on or about July 9, 2025, by Priority Mail, from the greater Los Angeles area. 4 Upon reviewing a scanned image of the Parcel’s 3F exterior, DiDomenico observed that, although the return address identified a business, “Vitamin Plus,” the mailing label was handwritten and the postage had 1 At the hearing, the State presented the testimony of DiDomenico. Defendant presented no witnesses. 2 DiDomenico could not recall the dates of those earlier parcels; he testified that such record reviews typically reach back no more than two years. 3 See also State’s Resp. to Def.’s Mot. to Suppress [hereinafter “State’s Resp.”] ¶ 3 (identifying the Lincoln address as 10309 Greentop Road and the addressee as “Aubree Gibbs”); Def.’s Mot. to Suppress [hereinafter “Def.’s Mot.”] ¶ 1 (identifying the Parcel by USPS tracking number 9505513803765190777039). 4 See Def.’s Mot. ¶ 1. 2 been paid in cash. 5 On July 10, 2025, DiDomenico ran the names and addresses on 4F the Parcel through CLEAR, a database that postal inspectors use to verify names, addresses, dates of birth, and telephone numbers. CLEAR did not associate the purported sender with the return address, and it did not associate Ms. Gibbs with the Lincoln address. On cross-examination, DiDomenico acknowledged that Detective Tillman’s report dated July 12, 2025, lists Ms. Gibbs at the Lincoln address, and he surmised that CLEAR had returned no match because Ms. Gibbs may be a minor. 5. The Parcel arrived at the USPS processing and distribution center in Wilmington on July 11, 2025. Its scheduled delivery date was July 12, 2025. DiDomenico took the Parcel in hand at the facility, placed it in a lineup with other parcels, and contacted Trooper Adkins of the Delaware State Police, a canine handler, who came to the facility as soon as he was able. Within a few hours, on the same day, the canine sniff was conducted. 6 A search warrant for the Parcel was 5F sought that same day and was obtained, and the Parcel was opened pursuant to the warrant. 7 Defendant was arrested on July 11, 2025. 6F 6. Defendant filed the instant motion on June 22, 2026, contending that the Parcel was seized without a warrant and without reasonable suspicion, probable cause, or any particularized and objective basis, and that he has standing to challenge the seizure because the State alleges that the Parcel was his and was intended for his receipt. 8 At the hearing, Defendant added that Article I, § 6 of the Delaware 7F Constitution should be construed to permit his challenge even if the Fourth 5 DiDomenico testified that businesses ordinarily use printed labels rather than handwritten ones, and that cash payment is a significant indicator of a narcotics parcel because it leaves no paper trail leading back to the sender. 6 Defendant has not challenged the canine’s training or reliability. See Def.’s Mot. ¶¶ 1–5. 7 Defendant challenges only the warrantless seizure, not the sufficiency of the warrant itself. Def.’s Mot. ¶¶ 2–3. 8 See Def.’s Mot. ¶¶ 2–4 (citing United States v. Terriques, 319 F.3d 1051 (8th Cir. 2003), and United States v. Colon, 386 F. App’x 229 (3d Cir. 2010)). 3 Amendment does not, because the State’s case rests on the allegation that Defendant possessed the Parcel’s contents, and he argued that the information relayed by Detective Tillman proved inaccurate and that the CLEAR results were mistaken. The State contends that Defendant lacks standing because he was neither the sender nor the addressee of the Parcel; that removing the Parcel from the mail stream and subjecting it to a canine sniff on the same day was not a seizure at all; and that, in any event, the detention was supported by reasonable articulable suspicion. 9 8F 7. Generally, a defendant who moves to suppress evidence bears the burden of establishing that the challenged search or seizure violated his constitutional rights. 10 For a warrantless search or seizure, the “State has the burden of proof of 9F showing the propriety of the search,” 11 i.e., the legality of the search or seizure, by 0F a preponderance of the evidence. 12 Before assessing the reasonableness of the police 11F conduct, however, the Court must first determine whether the defendant has a right to contest the search or seizure; if the defendant does not have standing, the Court need not determine the propriety of the police conduct. 13 Moreover, the defendant 12F bears the burden of establishing that personal interest. 14 13F 8. Fourth Amendment rights “are personal rights which . . . may not be vicariously asserted.” 15 A defendant may challenge a search or seizure only if he 14F had a legitimate expectation of privacy in the place or thing searched, or a possessory 9 See State’s Resp. ¶¶ 2–4. 10 State v. Medina, 2020 WL 104323, at *3 (Del. Super. Jan. 7, 2020). 11 State v. Henderson, 906 A.2d 232, 235 (Del. Super. 2005). See also Medina, 2020 WL 104323, at *3; State v. Garnett, 2021 WL 6109797, at *3 (Del. Super. Dec. 23, 2021), aff’d, 308 A.3d 625 (Del. 2023). 12 Garnett, 2021 WL 6109797, at *3. 13 Hanna v. State, 591 A.2d 158, 162 (Del. 1991). 14 Rakas v. Illinois, 439 U.S. 128, 130 n.1 (1978); Rawlings v. Kentucky, 448 U.S. 98, 104–05 (1980); see also State v. Mobley, 2001 WL 392459, at *2 (Del. Super. Apr. 5, 2001). 15 Rakas, 439 U.S. at 133–34 (quoting Alderman v. United States, 394 U.S. 165, 174 (1969)). 4 interest in the thing seized. 16 Sealed letters and parcels are “effects” within the 15F meaning of the Fourth Amendment, and the public has a legitimate expectation of privacy in their contents while they are in the mail. 17 That expectation belongs to 16F the sender and the addressee of the parcel. A person who is neither the sender nor the addressee generally has no such expectation, and the mere fact that he expects ultimately to receive the parcel’s contents does not supply one. 18 Applying that rule, 17F this Court held in State v. Staten that a defendant who was neither the sender nor the addressee of a package lacked a legitimate expectation of privacy in it, even though he had offered a codefendant $1,000 to retrieve the package on his behalf. 19 Courts 1 F have recognized an exception where a parcel is addressed to a fictitious name or alias that the defendant uses as his own, 20 but that exception depends on evidence 19F connecting the defendant to the name on the label. 9. Defendant was neither the sender nor the addressee of the Parcel. The Parcel was sent by a purported business in California to Ms. Gibbs, who, according to Detective Tillman’s report, resided at the Lincoln address, a residence other than Defendant’s own. Defendant presented no evidence that he arranged the shipment, that Ms. Gibbs’s name was used as his alias, that he had previously received parcels 16 Righter v. State, 704 A.2d 262, 265 (Del. 1997) (en banc) (citing Rakas, 439 U.S. at 143); Everett v. State, 186 A.3d 1224, 1235 (Del. 2018) (citing Byrd v. United States, 584 U.S. 395, 403 (2018)). 17 Ex parte Jackson, 96 U.S. 727, 733 (1878); United States v. Jacobsen, 466 U.S. 109, 114 (1984). 18 United States v. Givens, 733 F.2d 339, 341–42 (4th Cir. 1984); United States v. Pierce, 959 F.2d 1297, 1303 (5th Cir. 1992); United States v. Rose, 3 F.4th 722, 727–30 (4th Cir. 2021); see also United States v. King, 2022 WL 141553, at *8 (M.D. Pa. Jan. 14, 2022) (“[T]he expectation of privacy in a sealed package . . . resides only with the sender and addressee of the package; the individual a package is ‘ultimately intended for’ does not possess a reasonable expectation of privacy as to the package.”), aff’d, 2025 WL 1693055 (3d Cir. June 17, 2025), cert. denied, No. 25-5764 (U.S. Nov. 10, 2025). 19 2006 WL 337045, at *2 (Del. Super. Feb. 15, 2006). 20 See, e.g., United States v. Villarreal, 963 F.2d 770, 774 (5th Cir. 1992); United States v. Moorer, 2002 WL 1268044, at *2–3 (D. Del. May 10, 2002) (finding standing where the parties stipulated that a package addressed to a fictitious person was intended for the defendant, and the defendant had a key to the delivery residence, kept property and received mail there, and arrived shortly after delivery to collect the package). 5 in her name, that he controlled mail delivered to the Lincoln address, or that he had any right to exclude others from the Parcel while it remained in the custody of USPS. The only evidence connecting Defendant to the Parcel is DiDomenico’s testimony that the Parcel was being tracked from the same IP address as a parcel bound for Defendant’s residence. Evidence that a defendant took an interest in the progress of a parcel addressed to someone else, like the arrangement to retrieve the package in Staten, may show that he expected to receive its contents, but an expectation of receiving the contents of a container addressed to another person is not a legitimate expectation of privacy in that container. 21 Defendant therefore has not carried his 20F burden of establishing a protected interest in the Parcel. 10. Defendant’s principal response is that the State cannot have it both ways: it cannot charge him with possessing the contents of the Parcel while denying that he had any interest in the Parcel. The United States Supreme Court considered and rejected that very argument in United States v. Salvucci, 22 in which it abandoned the 21F “automatic standing” rule for possessory offenses and held that a defendant charged with a possessory crime, like any other defendant, may claim the benefit of the exclusionary rule only if his own Fourth Amendment rights were violated. 23 The 22F Delaware Supreme Court has applied the same principle, noting that a finding that a defendant lacked a legitimate expectation of privacy in a container “is not inconsistent with his conviction for possession of the contents.” 24 3F 11. Defendant’s reliance on Article I, § 6 does not change the result. Delaware courts analyze suppression motions separately under Article I, § 6 “only when a 21 Staten, 2006 WL 337045, at *2; see also Givens, 733 F.2d at 341–42; King, 2022 WL 141553, at *8. 22 448 U.S. 83 (1980). 23 Id. at 85, 88–92 (overruling Jones v. United States, 362 U.S. 257 (1960)); see also Rawlings, 448 U.S. at 104–06. 24 Robertson v. State, 596 A.2d 1345, 1353 (Del. 1991) (citing Salvucci, 448 U.S. at 92). 6 party produces particular and detailed explanations of why a separate analysis is appropriate.” 25 Defendant has offered no such explanation. He has not pointed to 24F the text or history of Article I, § 6, to any decision of the Delaware Supreme Court, or to any other consideration that would support departing from the settled rule that a defendant must establish his own protected interest before the Court will examine the legality of a search or seizure. Nor has Defendant cited any Delaware decision adopting an automatic standing rule under the Delaware Constitution. The Court declines to adopt one here. Because Defendant lacks standing, the motion must be denied on that ground alone. 26 25F 12. Even if Defendant could challenge the detention of the Parcel, the Court would deny the motion because the detention was reasonable. The State acknowledges that no warrant authorized the initial removal of the Parcel from the mail stream, 27 but it contends that no seizure occurred at all, because DiDomenico’s 26F handling of the Parcel at the processing facility, on the day before its scheduled delivery, did not meaningfully interfere with anyone’s possessory interest in it. 28 27F The Court need not resolve that question, and will assume, without deciding, that DiDomenico seized the Parcel when he removed it from the mail stream and held it for the canine sniff. 25 State v. Brown, 287 A.3d 1222, 1230 (Del. Super. 2023) (quoting Backus v. State, 202 A.3d 1126, 2019 WL 327963, at *3 (Del. Jan. 23, 2019) (ORDER)); see also Jones v. State, 745 A.2d 856, 864–65 (Del. 1999) (identifying the considerations relevant to whether Article I, § 6 should be construed more broadly than the Fourth Amendment). 26 Hanna, 591 A.2d at 162. 27 State’s Resp. ¶ 2. 28 See Jacobsen, 466 U.S. at 113 (a seizure of property occurs “when there is some meaningful interference with an individual’s possessory interests in that property”); United States v. England, 971 F.2d 419, 420–21 (9th Cir. 1992) (holding that setting a parcel aside for a canine sniff that did not delay its delivery was not a seizure); see also State v. Miller, 2001 WL 1486172, at *4 (Del. Super. Sept. 11, 2001). 7  13. Officers may briefly detain a mailed parcel, on reasonable articulable suspicion that it contains contraband, for the purpose of a canine sniff or another minimally intrusive investigation designed to confirm or dispel that suspicion; only the opening of the parcel requires probable cause and a warrant. 29 A canine sniff of 28F a lawfully detained parcel is not itself a search, because it discloses only the presence or absence of contraband. 30 Reasonable articulable suspicion “is a less stringent 29F standard than the probable cause standard and requires a quantum of proof that is less than preponderance of the evidence.” 31 The Court evaluates “the totality of the 30F circumstances as viewed through the eyes of a reasonable, trained police officer in the same or similar circumstances, combining objective facts with such an officer’s subjective interpretation of those facts,” 32 considers only the facts known to the 31F officer when the detention began, 33 and defers to the experience and training of law 32F enforcement officers. 34 Facts individually consistent with innocent conduct may, 33F taken together, warrant further investigation. 35 34F 14. When DiDomenico removed the Parcel from the mail stream on July 11, 2025, he knew the following: (1) the Delaware State Police had an ongoing narcotics investigation of Defendant, in the course of which investigators had received information that Defendant expected a cocaine shipment by mail; (2) USPS records 29 United States v. Van Leeuwen, 397 U.S. 249, 252–53 (1970); United States v. Place, 462 U.S. 696, 706 (1983); State v. Ellison, 1998 WL 731584, at *4–5 (Del. Super. Aug. 13, 1998); Miller, 2001 WL 1486172, at *4–5; United States v. Golson, 743 F.3d 44, 55 (3d Cir. 2014) (“Postal authorities may seize and detain mailed items for a reasonable amount of time, if they have a reasonable suspicion of criminal activity.”); Colon, 386 F. App’x at 231. 30 Place, 462 U.S. at 707; Illinois v. Caballes, 543 U.S. 405, 409 (2005). 31 Swanson v. State, 351 A.3d 496, 510 (Del. 2025) (quoting Purnell v. State, 832 A.2d 714, 719 (Del. 2003)). 32 Jones, 745 A.2d at 861; accord Flowers v. State, 195 A.3d 18, 27 (Del. 2018). 33 Swanson, 351 A.3d at 510. 34 Flowers, 195 A.3d at 27 (quoting Woody v. State, 765 A.2d 1257, 1262 (Del. 2001)); accord Swanson, 351 A.3d at 510. 35 United States v. Sokolow, 490 U.S. 1, 9–10 (1989); United States v. Arvizu, 534 U.S. 266, 273– 74 (2002). 8 showed that Defendant’s residence had received parcels from the greater Los Angeles area, a recognized source location for mailed narcotics, within the preceding two years; (3) the IP address that was tracking a parcel destined for Defendant’s residence was also tracking the Parcel; (4) the Parcel had been mailed by Priority Mail from the greater Los Angeles area; (5) although the return address identified a business, the label was handwritten and the postage had been paid in cash; and (6) a database search had failed to associate either the purported sender with the return address or the addressee with the delivery address. 15. Those facts, taken together, provided a particularized and objective basis for suspecting that the Parcel contained narcotics. The Parcel’s own characteristics—origin in a source location, Priority Mail service, a handwritten label from a purported business, cash postage, and an unverifiable sender—are the same indicators that this Court and the federal courts, including the Third Circuit, have repeatedly found sufficient to justify a brief detention for a canine sniff. 36 35F Indeed, both of the decisions on which Defendant relies upheld the detention of a parcel on comparable facts. 37 Standing alone, those characteristics might describe 36F some innocent parcels, but the Court does not consider them in isolation, and the 36 See Ellison, 1998 WL 731584, at *4–5 (handwritten label, cash payment, overnight service, California origin, and heavy wrapping); Miller, 2001 WL 1486172, at *5 (express service, handwritten label, significant weight, heavily taped seams, and cash payment, even without proof of a fictitious sender or a source city); Golson, 743 F.3d at 55 n.10 (fictitious and undeliverable return address, origin in a source state, and an addressee unknown at the delivery address); United States v. Ramos, 826 F. App’x 131, 133 (3d Cir. 2020) (origin in a source location, Priority Mail service, database results that matched neither the sender nor the addressee to their purported addresses, a mailing zip code different from that of the return address, and prior Priority Mail parcels from the same source location to the same address). 37 See Colon, 386 F. App’x at 231 (Express Mail service, origin in a source location, mailing from a post office outside the return address’s zip code, a database check showing that no one by the sender’s name lived at the return address, and heavy taping); Terriques, 319 F.3d at 1056–57 (heavily taped seams, a fictitious return address in a high-crime area, a label listing an individual’s name at a business address, and mailing from a postal facility some distance from the return address). 9 possibility of an innocent explanation does not preclude a finding of reasonable suspicion. 38 This case, moreover, involves more than a generic parcel profile: the 37F Parcel was being tracked from the same IP address as a parcel bound for the residence of a man under active investigation for narcotics distribution, whose residence had previously received parcels from the same source location, and who, according to information relayed by the investigating detective, was expecting narcotics by mail. 16. Defendant’s counterarguments do not alter that conclusion. First, Defendant argued at the hearing that no parcel arrived within the three-to-four-day window that Detective Tillman had described, and characterized the information relayed by Detective Tillman as false. The Court agrees that, on this record, that information cannot bear much weight on its own. Detective Tillman did not testify, DiDomenico did not know the identity of the source or the basis of the source’s knowledge, and the State offered no evidence of the source’s past reliability. 39 Nor 8F can the collective knowledge doctrine supply what the record lacks: although an officer may act on a fellow officer’s request without being apprised of the underlying facts, the State must still show that the officer who made the request possessed the requisite knowledge, and it presented no such evidence here. 40 DiDomenico, 39F 38 See Sokolow, 490 U.S. at 9–10; Arvizu, 534 U.S. at 274 (rejecting a “divide-and-conquer analysis” of the factors supporting reasonable suspicion); cf. Lefebvre v. State, 19 A.3d 287, 293 (Del. 2011) (“That hypothetically innocent explanations may exist for facts learned during an investigation does not preclude a finding of probable cause.”). 39 See Swanson, 351 A.3d at 511 (in assessing an informant’s tip, a court considers the reliability of the informant, the details contained in the tip, and the degree to which the tip is corroborated by independent police investigation); Valentine v. State, 207 A.3d 566, 572 (Del. 2019) (conclusory assertion that an informant was “past proven reliable,” without facts explaining that reliability, was insufficient). 40 See State v. Cooley, 457 A.2d 352, 355 (Del. 1983) (an arresting officer “need not be apprised of the underlying circumstances” and “can act in the belief that his fellow officer’s judgment is correct,” but information never communicated among officers cannot be pooled to supply probable cause); Gordon v. State, 245 A.3d 499, 511–12 (Del. 2021) (en banc) (collective knowledge doctrine properly applied where the detectives who possessed reasonable suspicion communicated 10 however, did not act on that information alone. He detained the Parcel only after his own investigation—the USPS delivery records, the IP-address link, and the Parcel’s physical characteristics—had corroborated the core assertion that a narcotics parcel connected to Defendant would arrive by mail. That corroboration went to criminality, not merely to Defendant’s identity or address, and Delaware law draws precisely that distinction. 41 When an informant “is right about some things, he is 40F more probably right about other facts.” 42 That a parcel arrived some two weeks, 41F rather than four days, after Detective Tillman’s call does not render the information false; it means only that the prediction of timing was imprecise. Information of unknown reliability may contribute to reasonable suspicion when independent police work corroborates it, 43 and reasonable suspicion “can arise from information that is 42F less reliable than that required to show probable cause.” 44 In any event, the Court 43F would reach the same conclusion if it disregarded the relayed information entirely, because the existence of the investigation, the delivery history of Defendant’s residence, the IP-address link, and the Parcel’s characteristics would suffice without it. 17. Second, Defendant contends that the CLEAR results were wrong, because Ms. Gibbs in fact resided at the Lincoln address. Reasonable suspicion is assessed on the facts as they reasonably appeared to the officer at the time of the detention, with the trooper and requested the stop); State v. Holmes, 2015 WL 5168374, at *4–6 (Del. Super. Sept. 3, 2015) (State must prove either that the acting officers themselves possessed the requisite knowledge or that an officer who possessed it communicated it to them or directed their action). 41 LeGrande v. State, 947 A.2d 1103, 1111 (Del. 2008); McKinney v. State, 107 A.3d 1045, 1049 (Del. 2014) (en banc); see also State v. Taylor, 341 A.3d 568, 576 (Del. Super. 2025) (distinguishing corroboration of a defendant’s identity from corroboration of criminality). 42 Illinois v. Gates, 462 U.S. 213, 244 (1983) (quoting Spinelli v. United States, 393 U.S. 410, 427 (1969) (White, J., concurring)). 43 Alabama v. White, 496 U.S. 325, 330–32 (1990); Swanson, 351 A.3d at 511, 515; see also Miller v. State, 25 A.3d 768, 773–74 (Del. 2011). 44 White, 496 U.S. at 330; accord Swanson, 351 A.3d at 515. 11 and “[t]o be reasonable is not to be perfect”; the Fourth Amendment tolerates reasonable mistakes of fact. 45 DiDomenico’s reliance on a database that postal 44F inspectors routinely use for this purpose was reasonable, and Defendant has not shown that DiDomenico knew, or should have known, before he detained the Parcel that the result was mistaken. Moreover, Defendant did not rebut DiDomenico’s testimony that CLEAR likewise failed to associate the purported sender with the return address. Even if the Court gave no weight to the database results at all, the remaining facts would suffice. 18. The detention was also reasonable in scope and duration. The reasonableness of an investigative detention of property depends on its length, the purpose it served, and whether the officers diligently pursued a means of investigation likely to confirm or dispel their suspicion quickly. 46 DiDomenico 5F removed the Parcel from the mail stream on July 11, immediately contacted a canine handler, and obtained the sniff within a few hours; a warrant was sought the same day; and all of this occurred before the Parcel’s scheduled delivery date of July 12. The United States Supreme Court has upheld a twenty-nine-hour detention of mailed parcels where investigators acted diligently, 47 the Third Circuit has upheld a 46F detention of four days, 48 and this Court has found a detention of less than two hours 47F reasonable where the parcel was delivered on schedule. 49 The few hours at issue 48F here, which caused no delay in delivery, fall comfortably within those limits. The 45 Heien v. North Carolina, 574 U.S. 54, 60–61 (2014); see also Illinois v. Rodriguez, 497 U.S. 177, 185–86 (1990). 46 Place, 462 U.S. at 709–10; United States v. Sharpe, 470 U.S. 675, 685–86 (1985). 47 Van Leeuwen, 397 U.S. at 252–53. 48 Golson, 743 F.3d at 55–56. 49 Ellison, 1998 WL 731584, at *5. 12 Parcel was not opened until a warrant issued, and Defendant does not challenge that warrant. 50 49F 19. In sum, Defendant has not established a protected interest in a parcel that he neither sent nor received, and the Court declines to create an automatic standing rule under Article I, § 6. Moreover, even if Defendant had standing, the Parcel was briefly and diligently detained on reasonable articulable suspicion and was opened only after a warrant issued. WHEREFORE, in light of the foregoing considerations, Defendant Garron D. Wescott’s Motion to Suppress is DENIED. IT IS SO ORDERED. Via email oc: Prothonotary cc: Counsel of Record 50 See Van Leeuwen, 397 U.S. at 253 (privacy interest in first-class mail “was not disturbed or invaded until the approval of the magistrate was obtained”); Def.’s Mot. ¶¶ 2–3. 13