State v. Girdler
In State v. Girdler, 138 Ariz. 482, 484-85, 675 P.2d 1301, 1303-04 (1983), the defendant set fire to his mobile home, with his wife and children inside, and was convicted of arson of an occupied structure and felony murder.
An officer and prosecutor went to the residence without a warrant and measured the time it took "to go from the back door of the burned-out mobile home to the defendant's car." Id. at 486, 675 P.2d at 1305.
The court concluded the defendant did not have a reasonable expectation of privacy in that area because, "from a photograph of the premises, it is obvious that the area was open to the public." Id. at 487, 675 P.2d at 1306.