Phone calls in juvenile detention were properly recorded. Defendant was on notice of recording. Commonwealth v. Odgren, 483 Mass. 41 (Sept. 4, 2019).
In an immigration case where the petitioner bears the burden of showing an egregious violation of the Fourth Amendment to suppress, he must file an affidavit in support of his prima facie case.
Ramirez-Aguilar v. Barr, 2019 U.S. App. LEXIS 26889 (2d Cir. Sept. 6, 2019).