Defendant left a camera disguised as a cell phone charger in a Starbucks bathroom. It was found by a customer and turned over to the store manager. The manager believed it to be a camera, opened the back, and found an SD card, and called the police. A man came to claim it, and they said it had been turned over to the police. They found him in the security video, and he was also on the SD card placing the camera. Video of patrons going to the toilet were on the card. Defendant had no reasonable expectation of privacy in the camera left in the bathroom. It was effectively abandoned. State v. Ipsen, 288 Ore. App. 395, 2017 Ore. App. LEXIS 1285 (Oct. 25, 2017).
Defendant waived any Fourth Amendment claim by his guilty plea, and he significantly benefitted from the plea. Hoskin v. United States, 2017 U.S. Dist. LEXIS 177752 (S.D. Fla. Oct. 25, 2017).*