In Villarreal v. State, 935 S.W.2d 134 (Tex. Crim. App. 1996), the defendant spent an hour or two at an associate's house to arrange a business transaction, returned approximately two hours later, and "rushed into the residence to avoid arrest" after the police officers monitoring the house identified themselves and warned Villarreal and two others to stop unloading packages from their vehicle. Id. at 136, 139. In the ensuing search of the house, officers discovered marijuana, firearms, a large quantity of cash, cocaine, and drug paraphernalia. Id. at 136. In holding that Villarreal's subjective expectation of privacy was not one that society was prepared to recognize as objectively reasonable, the plurality relied on Villarreal's failure to present evidence that: (1) he had a property or possessory interest in, or unrestricted access to, the house; (2) he had dominion or control over the residence or the right to exclude others; (3) he intended to stay overnight at the house. Id. at 139. Under these circumstances, this "casual visitor" did not have standing to challenge the search of the house. Id. at 137, 139. In Villarreal v. State, the Court of Criminal Appeals refused to categorize the appellant as an overnight guest despite his actual, subjective expectation to privacy in his friend's house. Villarreal, 935 S.W.2d at 137. The court reasoned the appellant was not entitled to challenge the search of the premises because he had no proprietary or possessory interest in the premises, lacked control over entrances and exits, had no clothing or personal items stored there, and did not demonstrate intent to stay the night, despite an invitation to do so. Id.