Defendants were involved in store thefts with a “booster bag” where they were going into the stores and making off with stuff in bag and then transferring it to a rolling suitcase on the street. When the police observed a theft and confronted them outside a store, there was a scuffle and they were handcuffed. The search incident of the bags was reasonable because they were within the grabbable area around them. People v. Harris, 2019 NY Slip Op 05099, 2019 N.Y. App. Div. LEXIS 5080 (1st Dept. June 25, 2019).
Plaintiff state prisoner doesn’t state a Fourth Amendment claim that his grievances couldn’t be read by an interloping guard. There’s no reasonable expectation of privacy in a prison or from that. Patterson v. Quiros, 2019 U.S. Dist. LEXIS 105295 (D.Conn. June 24, 2019).*