TX4: Def’s wife had joint use of iPad so she could deliver it to the police

“Even if we assume the Fourth Amendment was implicated when Gonzalez’s wife showed the iPad videos to the police, Gonzalez’s wife had apparent authority to permit police to view the iPad videos because she brought the iPad from her family’s home and entered the iPad’s passcode to present Gonzalez’s videos to the police. … It was objectively reasonable for the officers to believe Gonzalez’s wife had the authority to disclose the contents of the iPad to the police.” Gonzalez v. State, 2020 Tex. App. LEXIS 5870 (Tex. App. – San Antonio July 29, 2020).*

Defendant on post-conviction doesn’t show that defense counsel was ineffective for not filing a motion to suppress that had no merit. Patterson v. State, 2020 Fla. App. LEXIS 10767 (Fla. 2d DCA July 29, 2020).*

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