LA2: No REP in text messages in another person’s cell phone

Defendant had no reasonable expectation of privacy in text messages in another person’s cell phone. State v. Young, 2018 La. App. LEXIS 110 (La. App. 2 Cir. Jan. 18, 2018).

Defendant was on parole and his parole agreement required he wear a GPS monitor, and it showed him frequenting the homes of known drug dealers. That with a CI’s information was probable cause for an automobile search of his car. State v. Fisher, 2018 Iowa App. LEXIS 16 (Jan. 16, 2018).*