A state licensed private security guard was not a state actor under the Fourth Amendment when he searched defendant’s cell phone trying to determine the owner. State v. Simpson, 2020 Tenn. Crim. App. LEXIS 594 (Sept. 1, 2020).
“Additionally, we agree with the Supreme Court that the redactions to the search warrant application and hearing minutes were necessary to protect the anonymity of the confidential informant and to protect him or her from danger.” People v. Hedrington, 2020 NY Slip Op 04859, 2020 N.Y. App. Div. LEXIS 4939 (2d Dept. Sept. 2, 2020).*