First Circuit: US v. Stokes


Fourth Amendment, Sentencing


Where deft doesn't establish knowledge of behind-the-scenes arrangement at Post Office, no reasonable expectation of privacy for materials in post office box.

Where not appearing on the envelope as the sender or addressee, deft has no privacy interest in the sealed letters absent a showing of connection.

Affidavits and images of the seized envelopes addressed to the deft suffices to prove that the envelopes have not been opened.

No clear error in loss findings for sentencing, since, even if individual records were proved to be unrelated, the breadth of the scheme suggests that there were losses outside the record.

US v. Stokes