Defendant essentially waived his reasonable expectation of privacy in his computer hard drive when he took it in for repair, was told that the hard drive was failing and he needed a new one, and then directed them to move all the files to the new hard drive. This was a private search. Commonwealth v. Shaffer, 2017 PA Super 404, 2017 Pa. Super. LEXIS 1077 (Dec. 21, 2017).
Defendant, represented by counsel, filed two motions to suppress pro se. They are ordered stricken because he does not have hybrid representation. United States v. Jackson, 2017 U.S. Dist. LEXIS 211071 (S.D. Ill. Dec. 22, 2017).*
Defendant pro se motion to suppress while represented by counsel was properly rejected. People v. Tuff, 2017 NY Slip Op 08971, 2017 N.Y. App. Div. LEXIS 9078 (4th Dept. Dec. 22, 2017).