W.D.Tenn.: Def had a reasonable expectation of privacy in iPad even though family and housekeeper had password

Defendant had a reasonable expectation of privacy in his iPad that was in his house despite the fact that others in the home, including the housekeeper, had the password. The housekeeper saw likely child pornography and told the police, and she was a citizen informant. United States v. Friar, 2016 U.S. Dist. LEXIS 36148 (W.D.Tenn. Feb. 12, 2016), adopted 2016 U.S. Dist. LEXIS 35775 (W.D.Tenn. March 18, 2016).

Defense counsel was not ineffective for not briefing his search and seizure issue where a motion was filed and a hearing held. All the arguments were raised and addressed by the court, and the lack of a brief doesn’t mean that the outcome would be different. Defendant doesn’t point to any additional arguments that could have been made and weren’t which would have been successful. United States v. Wilson, 2016 U.S. Dist. LEXIS 36576 (W.D.Mich. March 21, 2016).