The United States Supreme Court held that the Fourth Amendment contains no co-conspirator exception and maintained that the proper determination is whether each respondent had either a property interest or a reasonable expectation of privacy which was invaded by the search and seizure.
United States v. Padilla, 113 S. Ct. 1936 (1993).
James M. Ginocchi,
Constitutional Law - Fourth Amendment - Search and Seizure - Standing - Co-Conspirator Exception,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol32/iss4/11