shipped drugs in sealed 55-gallon containers. The shipper notified customs officials after becoming suspicious of the contents of the drums. Without first obtaining a warrant, customs agents opened the drums and discovered the drugs. The court found that the defendants had a reasonable expectation of privacy in the sealed drums and that the agents’ search of the drums violated the defendants’ Fourth Amendment rights. Id. at 774-75. Crowder’s reliance on Villarreal is misplaced. The court in Villarreal consistently referenced a reasonable expectation of privacy in “closed containers.” See, e.g., id. at 773-74 (“Individuals do not surrender their expectations of privacy in closed containers when they send them by mail or common carrier.” (citing Jacobsen, 466 U.S. at 114, 104 S.Ct. 1652 (<HOLDING>))); id. at 774 (“The drum opened by the customs
recognizing record supported determination that defendant lacked expectation of privacy in house recognizing a reasonable expectation of privacy in betters and other sealed packages holding that the defendant had a reasonable expectation of privacy in a telephone booth holding that society recognizes a reasonable expectation of privacy holding that prisoners do not have a reasonable expectation of privacy in their cells