What is the burden of proving an illegal search or seizure violates a person's privacy?

"An illegal search or seizure violates the federal constitutional rights only of those who have a legitimate expectation of privacy in the invaded place or seized thing. [Citation.] The legitimate expectation of privacy must exist in the particular area searched or thing seized in order to bring a Fourth Amendment challenge. [Citations.] A defendant bears the burden to show he had such an expectation. [Citations.]" (People v. Hernandez (1988) 199 Cal.App.3d 1182, 1189, 245 Cal.Rptr. 513, emphasis omitted.) The burden is bipartite, consisting of a subjective and an objective component. "[T]here is a twofold requirement, first that a person have exhibited an actual (subjective) expectation of privacy and, second, that the expectation be one that society is prepared to recognize as 'reasonable.' " (Katz v. United States (1967) 389 U.S. 347, 361, 88 S.Ct. 507, 516, 19 L.Ed.2d 576 (conc. opn. of Harlan, J.).)