CA3: State court loss of suppression motion as private search was collateral estoppel to § 1983 case

Plaintiff was a student in a private university, and the RA in his dorm smelled burning marijuana in the hallway and narrowed it to plaintiff’s room. The next day, university security searched his room, and he was charged in the local Pennsylvania state courts. He moved to suppress the search and lost in the trial court on the ground this was a private search. He later sued under § 1983. His suit was barred by collateral estoppel from the state court finding it was a private search. He doesn’t get to relitigate it. Smith v. Susquehanna Univ., 2017 U.S. App. LEXIS 12538 (3d Cir. July 13, 2017).