Rankin v. State
In Rankin v. State, 57 Ark. App. 125, 942 S.W.2d 867 (1997), the Arkansas Court of Appeals held that a defendant who frequently stayed overnight at his girlfriend's apartment and left prescriptions and medicine bottles there did not have a reasonable expectation of privacy in the apartment when he was not an overnight guest when the search occurred.
In fact, the defendant was not inside the apartment when the search was conducted.
There was no evidence that he maintained control over the apartment.