The trial court’s findings of fact and conclusions of law were completely wrong. Defendant had no reasonable expectation of privacy concerning his jail calls made over a television monitor and through a computer system. This was a case of consent under the state wiretap statute to the recordings because every call starts with a warning it could be recorded. Commonwealth v. Byrd, 2018 PA Super 102, 2018 Pa. Super. LEXIS 406 (Apr. 30, 2018).
Defendant’s effort to hide a gun in his carport, visible from outside the carport, satisfied exigent circumstances for an entry into the curtilage. United States v. Rodriguez, 2018 U.S. Dist. LEXIS 72050 (S.D. Fla. Apr. 30, 2018).*