In United States v. Salvucci, 448 U.S. 83 (1980), the United States Supreme Court overruled Jones v. United States, 362 U.S. 257 (1960), eliminating the rule that a criminal defendant automatically has standing under the fourth amendment to challenge the legality of a search that yielded evidence that incriminated him. Salvucci held that a defendant must first establish a reasonable expectation of privacy in the premises before he may assert that his fourth amendment rights have been violated by improper intrusion into those premises.