Defendant’s motion changed from probable cause to arrest to whether there was an unreasonable search and seizure between the suppression hearing and the appeal. Thus, the issue for appeal wasn’t presented to the trial court, so it’s not preserved for appeal. State v. Howard, 2018 La. App. LEXIS 1786 (La. App. 1 Cir. Sep. 21, 2018).
A Dominican Republic wiretap’s product made it into a wiretap allegation in Massachusetts. Even if that was an unlawful wiretap, defendant doesn’t allege his own conversations were ever captured. Therefore, no standing. United States v. Marte, 2018 U.S. Dist. LEXIS 162581 (D. Mass. Sep. 24, 2018).*