establish “a legitimate expectation of privacy in the particular area[ ] of the [vehicle] searched,” based on either a property or possessory interest in the vehicle itself or an interest in the pi’operty seized. Rakas v. Illinois, 439 U.S. 128, 148, 99 S.Ct. 421, 58 L.Ed.2d 387 (1978) (explaining that a passenger qua passenger would not normally have a legitimate expectation of privacy in the trunk, glove compartment, or area under the seat of a car); see also United States v. Eylicio-Montoya, 18 F.3d 845, 851 (10th Cir. 1994) (“A passenger may establish standing [to challenge a car search] by, inter alia, demonstrating some relationship to the vehicle sufficient to establish her lawful possession or control thereof.”); United States v. Jefferson, 925 F.2d 1242, 1249 (10th Cir.1991) (<HOLDING>); United States v. Erwin, 875 F.2d 268, 270-71
holding that a passenger has standing to challenge a stops constitutionality because the passenger is seized from the moment a car is stopped holding that the driver of a car who had permission to use the car had standing to challenge its search holding that appellants had no standing to challenge search of car because they had no ownership or possessory rights of any kind in the car holding that a passenger who lacked a property or possessory interest in the automobile or property seized lacked standing to challenge a search of the car holding a nonowner passenger claiming no interest in crack seized from the car had no standing to challenge the search