who was leaving house when officers arrived to execute arrest warrant for a third party, where premises warrant police secured after seizing defendant’s backpack did not specifically authorize search of defendant or her backpack); State v. Wynne, 552 N.W.2d 218, 220 (Minn.1996) (relying on Graham to invalidate search of purse taken from person arriving outside residence for which police had premises warrant after search already had commenced); State v. Andrews, 201 Wis.2d 383, 549 N.W.2d 210, 215-16, 218 (1996) (relying in part on Graham to hold that police executing premises warrant may not search items “worn by or in the physical possession of persons whose search is not authorized by the warrant” (footnote omitted)); Hayes v. State, 141 Ga.App. 706, 234 S.E.2d 360, 361-62 (1977) (<HOLDING>). The Seventh Circuit Court of Appeals reasoned
holding search of suitcase found next to man sleeping on couch was unconstitutional where officers had warrant for particular apartment and its occupant and failed prior to search to take reasonable steps to determine whether suitcase belonged to occupant named in warrant or to nonresident visitor holding anticipatory warrant for search of defendants home was invalid when defendant was required to pick up suitcase containing contraband at airport and there was no assurance at time warrant was issued that defendant would take suitcase to his home holding search invalid under the fourth amendment when a physicallypresent occupant expressly objected to a search  notwithstanding the consent of a fellow occupant holding anticipatory warrant for search of defendants home was invalid when defendant was required to pick up suitcase containing contraband at airport and there was no information indicating defendant would take suitcase home or otherwise linking defendants residence to illegal activity holding that search of appellants suitcase found on the floor next to the couch on which he was sleeping was an unconstitutional search of his person and was not authorized by a search of the residence