A security guard employed by the Chicago Housing Authority was not a state actor. There is already precedent in this circuit. United States v. Green, 2020 U.S. App. LEXIS 29421 (7th Cir. Sept. 16, 2020).
The SDNY searched defendant’s emails after the Manhattan DA did without a search warrant. This came up during a post-trial discovery dispute. The court considers, but does not have to decide, that the Fourth Amendment might have come out in defendant’s favor if this had been disclosed during the suppression litigation, but the question is moot in light of the court granting a motion to dismiss with prejudice for a discovery violation of a document being disclosed in mid-trial they had for nearly a decade and then they quibbled over whether to disclose. [This is a black-eye for the vaunted SDNY USAO.] United States v. Nejad, 2020 U.S. Dist. LEXIS 169686 (S.D. N.Y. Sept. 16, 2020).*