791 P.2d 880, 887 (Utah Ct.App.1990) ("Once the defendant has been put on notice that the State claims the warrantless search was constitutional because [the defendant] has no expectation of privacy in the area searched, then the defendant must factually demonstrate that he does have standing to contest the warrantless search."), overruled on other grounds by State v. Bisner, 2001 UT 9 r passengers have a legitimate expectation of privacy in their coats or jackets found in cars. See People v. Armendarez, 188 Mich.App. 61, 468 N.W.2d 893, 900 (1991) (finding that car passenger had "standing to object to the search of his personal effects in the car, namely, his coat," where his coat was found on front seat of vehicle); State v. McCarthy, 258 Mont. 51, 852 P.2d 111, 112-13 (1993) (<HOLDING>). 1 11 Finally, other jurisdictions have found
holding that the owner of a shoulder bag located on the front seat of his girlfriends car had a legitimate expectation of privacy in the bag and its contents holding that car passenger whose purse was found on floor behind drivers seat and searched had standing because a purse is clearly a container in which a person has a legitimate expectation of privacy holding that car passenger had legitimate expectation of privacy in his jacket found crumpled on the back seat of car holding that a car passenger had a legitimate expectation of privacy in his closed plastic shopping bag found on the floor of the car holding that a car passenger had a reasonable expectation of privacy in his closed brown paper bag found on the floorboard of his companions car