LA1: Probationer wearing GPS ankle monitor has no REP in information about his movements

A probationer wearing a GPS ankle monitor has no reasonable expectation of privacy in the information that linked him to an armed robbery while he was on probation. State in the interest of T.B., 2021 La. App. LEXIS 188 (La. App. 1 Cir. Feb. 19, 2021).

“For similar reasons, the [Hudson v. Palmer] Court held that ‘the Fourth Amendment does not protect against seizures in a prison cell[.]’ Id. at 528 n.8. According to the Court, “[p]rison officials must be free to seize from cells any articles which, in their view, disserve legitimate institutional interests.” Id. [¶] Applying Hudson to Plaintiff’s claim, the Fourth Amendment did not prohibit Ortiz and Miller from searching his cell or his personal belongings. Therefore, Plaintiff does not state a Fourth Amendment claim.” Stewart v. Horton, 2021 U.S. Dist. LEXIS 31019 (W.D. Mich. Feb. 19, 2021).*

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