NCMEC was a private entity and not a government actor. The government didn’t exceed the private search. United States v. Kendall, 2019 U.S. Dist. LEXIS 192442 (E.D. Ky. Nov. 6, 2019).
Defendant had no reasonable expectation of privacy in an alleyway where he hid something. United States v. Davis, 2019 U.S. Dist. LEXIS 192633 (W.D. Mo. Nov. 6, 2019).*
Defendant’s CSLI argument wasn’t preserved in the trial court. People v. Lanham, 2019 NY Slip Op 07905, 2019 N.Y. App. Div. LEXIS 7934 (2d Dist. Nov. 6, 2019).*