Defendant bought a Lexus from a used car dealer that had a GPS installed to track it, apparently to repossess it if necessary. He was warned on the purchase contract. Still, the government needed a search warrant to get access to the GPS information, and warrantlessly obtaining the GPS data from the provider in 2017, five years after Jones, was illegal. The lack of a trespass on the car, as in Jones, wasn’t material. In addition, the fact others drove the car on occasion didn’t matter. United States v. Diggs, 2019 U.S. Dist. LEXIS 80029 (N.D. Ill. May 13, 2019).
Defendant had no reasonable expectation of privacy in another person’s email account after he sent the emails. Apparently because it was easier to decide the merits than 2255 procedural default, the court finds there was no reasonable expectation of privacy. Handlon v. United States, 2019 U.S. Dist. LEXIS 80112 (M.D. Fla. May 13, 2019).*