Recordings made in defendant’s house were not relied upon in issuing the search warrant for his house, so they can’t be a basis of suppression under the wiretap statute. As a Fourth Amendment matter, under Hoffa, the recordings made inside are not unreasonable when the defendant consented to the entry and had the conversation. Under the state constitution, the court concludes that the information derived from the conversation, as opposed to the conversation itself, is not suppressible. “We emphasize that in our holding today, we offer no opinion on whether the recordings themselves violated Appellant’s constitutional rights under Article I, Section 8. In the event that Appellant’s rights actually were violated, suppression of the recordings themselves is no mere constitutional consolation prize.” Commonwealth v. Katona, 2018 PA Super 166, 2018 Pa. Super. LEXIS 655 (June 14, 2018).
A controlled buy of marijuana out of a house is nexus to the house even 70 days later. United States v. Delli, 2018 U.S. Dist. LEXIS 99705 (D. Utah June 14, 2018).*