Guests' Expectation of Privacy in Garages and Outbuildings

I’ve had a couple of questions recently about something that I’d never considered before: whether a guest has “standing” to contest a search of the outbuildings associated with a host’s home. Most readers will know the legal backdrop. In order to argue that the results of an allegedly illegal police search should be suppressed, a defendant must establish that he had a reasonable expectation of privacy in the location that was searched. Otherwise, he lacks standing to contest the search. An overnight guest generally has a reasonable expectation of privacy in the host's home. See Robert L. Farb, Arrest, Search, and Investigation in North Carolina 80 (3rd ed. 2003). A non-overnight guest, such as a dinner guest, may also have such an expectation, depending on the specific facts and circumstances of the case. Assuming that a guest has a reasonable expectation of privacy in a host’s home, does that expectation extends to outbuildings such as storage sheds and garages? I couldn't find a North Carolina appellate case on point, and the leading treatise doesn’t directly address the issue. See generally Wayne R. LaFave, Search and Seizure § 11.3(b)-(c) (4th ed. 2004). I was able find a number of out-of-state cases, which suggest that the answer is often no: United States v Mendoza, 438 F.3d 792 (7th Cir. 2006) (apparent overnight guest at a residence had no reasonable expectation of privacy in the detached garage where his vehicle was parked) United States v. Phillips, 382 F.3d 489 (5th Cir. 2004) (guest had [...]