MA: Disavowing ownership and possession of cell phone means no privacy interest in it

Defendant who placed a cell phone on a window sill expressly disavowing ownership and any desire for further possession of it had no reasonable expectation of privacy in its contents. Commonwealth v. Martin, 467 Mass. 291, 4 N.E.3d 1236 (2014).

There was a corporate entity of defendant involved in defendant’s alleged tax fraud scheme, and it was the target of a search. The court doubts his standing to challenge the search, but finds the warrant and its execution reasonable in any event. United States v. Sotolongo, 2014 U.S. Dist. LEXIS 25336 (M.D. Fla. February 26, 2014).*

2255 petitioner had a full and fair opportunity to litigate his Fourth Amendment claim in the main proceeding so he can’t on post-conviction. United States v. Punzalan, 2014 U.S. Dist. LEXIS 24203 (D. Guam February 24, 2014).*