FL1: No REP in cell phone video made by victim he knew was being recorded

Defendant had no reasonable expectation of privacy in a cell phone video he saw being recorded on his victim’s cell phone while he talked to her under the state wiretap law. Smiley v. State, 2019 Fla. App. LEXIS 12628 (Fla. 1st DCA Aug. 16, 2019).

Defendant’s theories that the search occurred before the search warrant issued are really just speculation. United States v. Thomas, 2019 U.S. Dist. LEXIS 138870 (D. D.C. Aug. 15, 2019).*