PA: Private university public safety conducted dorm searches for drugs after drug induced fight; it was a private search

Defendant was a student at Villanova University. There was a violent confrontation in a dorm between students who had admitted ingesting likely too much LSD. The University’s Public Safety Department and University officials conducted dorm searches. They had no arrest powers, and they carried no firearms or handcuffs. They turned over what they found to the local police, and defendant was prosecuted. The search was a private search. The local police weren’t in on the searches although the product came to them. Commonwealth v. Yim, 2018 PA Super 253, 2018 Pa. Super. LEXIS 1007 (Sep. 12, 2018).

Defendant can’t move to suppress his voice on a phone call without filing an affidavit with the motion that it’s his voice. He can’t rely on the government’s assertion that it’s him. United States v. Loera, 2018 U.S. Dist. LEXIS 155544 (E.D. N.Y. Sep. 12, 2018).

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