D.Haw.: Authorized third party’s access of def’s security video from cloud not unreasonable nor was a SW required

“The evolution of technology gives rise, in this particular case, to the question of whether a third-party’s access to a defendant’s personal home surveillance system stored in the cloud (that is, where managed remotely and made available to users over the internet) requires law enforcement first to obtain a search warrant before accessing, downloading and copying the digital video content. Under the facts of this case, an authorized user accessed the account containing the video content and showed it to the police. Therefore a warrant was not required.” United States v. Patrakis, 2017 U.S. Dist. LEXIS 211299 (D. Haw. Dec. 21, 2017).

A LPN check showed that the vehicle operator’s license was suspended, and that justified blocking its path. Because that was a custodial arrest situation, a search incident was proper.
United States v. Fullwood, 2017 U.S. Dist. LEXIS 210211 (W.D. N.C. Nov. 17, 2017).*