LA: No PC for warrantless entry and security cameras are not exigency

“Here, the trial court made credibility determinations based on the testimony of multiple officers involved in defendant’s arrest and found that officers lacked probable cause to search defendant’s residence. Furthermore, observation that defendant’s home had security cameras failed to amount to exigent circumstances to enter defendant’s home after officers arrested him for possession of a small quantity of marijuana near his residence. Thus, the trial court correctly suppressed the evidence recovered from the residence and the statements made by defendant following the illegal entry. Therefore, the court of appeal’s ruling is reversed.” State v. Shisler, 2020 La. LEXIS 765 (May 1, 2020), rev’g State v. Shisler, 286 So. 3d 1226 (La. App. 4 Cir. 2019). [Note: With video doorbells, millions of people have security cameras at home.).

Plaintiff prison inmate doesn’t state a Fourth Amendment claim for alleged violation of the N.C. Financial Privacy Act by state officials disclosing his prison accounts balances. Under United States v. Miller, it doesn’t matter how the information was disclosed because there was no reasonable expectation of privacy in them. The court declines to exercise supplemental jurisdiction over the state claim for violation of the Act. Neal v. State Employees Credit Union, 2020 U.S. Dist. LEXIS 81444 (E.D. May 8, 2020).