Defendant lacked standing to challenge the placing of the GPS tracking device on the package because she was neither the sender nor addressee of the package and demonstrated no reasonable expectation of privacy in the package. The police could validly search defendant’s purse because her arrest was lawful. State v. Evans, 2018-Ohio-744, 2018 Ohio App. LEXIS 785 (8th Dist. Mar. 1, 2018).
Psychotherapist’s alleged violation of confidentiality and his reasonable expectation of privacy in their conversations in ratting out defendant about his child pornography use was not state action. The report would not lead to suppression. Ravn v. State, 2018 Alas. App. LEXIS 45 (Mar. 5, 2018) (memorandum).