“[W]hen police search a home pursuant to a warrant obtained after a warrantless search, evidence obtained pursuant to the warrant need not be suppressed so long as: (1) a neutral magistrate would still have issued the warrant ‘even if not presented with information that had been obtained during [the] unlawful search;’ and (2) the first, illegal, search did not prompt the officers to obtain the search warrant. United States v. Herrold, 962 F.2d 1131, 1144 (3d Cir. 1992); see Stabile, 633 F.3d at 243; United States v. Perez, 280 F.3d 318, 339 (3d Cir. 2002). Both prongs are satisfied here.” United States v. Combs, 2018 U.S. App. LEXIS 5634 (3d Cir. Mar. 6, 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).