47, 37 P.3d 1073. 18 We have held that a driver of a car who has either an ownership interest in the car or "permissive, possessory control of the car" has standing to challenge a search of the car. Matison, 875 P.2d at 588 (quotations and citation omitted); Sepulveda, 842 P.2d at 915. However, a car passenger does not normally have standing to object to a search of the car absent an ownership or possessory interest in the car. See Rakas, 439 U.S. at 148-49, 99 S.Ct. at 433. In Rakas, the United States Supreme Court established that "a [ c. 192, 537 N.E.2d 13, 15 (1989) (concluding that a car passenger whose closed brown paper bag was found in car's trunk, and was searched by police, had standing to challenge search); Arnold v. Commonwealth, 17 Va.App. 313, 437 S.E.2d 235, 237 (1993) (<HOLDING>). " 10 Other jurisdictions have also held that
holding evidence did not connect defendant to narcotics found in individual bags inside a larger bag in a car following the defendants car when the only connection was his fingerprints on outer bag and when the driver and passenger of the car in which the drugs were found exhibited nervousness and other factors indicating consciousness of guilt 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 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