The search of defendant’s car for a weapon was justified by seeing the butt of the gun with a flashlight. Defendant’s car was stopped in a high-crime area, and a woman was leaning in the window, and that led the officer to conclude a hand-to-hand drug deal was happening. Defendant fled the vehicle when the officer approached. His handcuffing when he was caught was for safety reasons. He was a felon. State v. Williams, 47 So. 3d 455 (La.App. 5th Cir. 2010).*

Defense counsel filed an Anders brief after defendant’s plea, and he raised his search issue pro se, which was held waived by the guilty plea. State v. Turner, 2010 La. App. LEXIS 1071 (La.App. 5th Cir. July 27, 2010).*

In a civil rights/false arrest case, the officer had probable cause, or at least qualified immunity, for plaintiff’s arrest as a felon in possession without having to further investigate the status of the conviction which he was told about on a records check. Dickson v. City of Clovis, 2010 NMCA 58, 148 N.M. 831, 242 P.3d 398 (2010), cert. denied, 148 N.M. 582, 241 P.3d 180 (2010).*

Secret service agents had probable cause for the arrest of the plaintiff for lying to them about touching Vice President Cheney when he wanted to ask Cheney “How many kids have you killed today?” referring to the War in Iraq which offended a Secret Service agent protecting Cheney. Plaintiff, however, wins on his First Amendment retaliatory arrest claim. Howards v. McLaughlin, 634 F.3d 1131 (10th Cir. 2011)*:

In light of the care the Supreme Court took to distinguish between complex and ordinary retaliation claims, we are not persuaded Hartman applies to the circumstances here. See John Koerner, Note, Between Healthy and Hartman: Probable Cause in Retaliatory Arrest Cases, 109 Colum. L. Rev. 755, 771 (2009) (“[T]he Court did not signal that it was rejecting [the Mt. Healthy] standard in general. Instead, the Court stressed three factors that supported a heightened pleading standard in retaliatory prosecution cases: complex causation, evidentiary concerns, and the presumption of prosecutorial regularity.”). The alternative approach, extending the “no-probable-cause” requirement to this ordinary retaliatory arrest case and dismissing Mr. Howards’ suit, would result in the Court’s limited exception devouring the rule. Because we hold Hartman did not disturb our earlier precedent on ordinary retaliation cases, when Mr. Howards was arrested it was clearly established that an arrest made in retaliation of an individual’s First Amendment rights is unlawful, even if the arrest is supported by probable cause. Accordingly, our prior precedent permits Mr. Howards to proceed with his First Amendment retaliation claim notwithstanding probable cause existed for his arrest. See DeLoach, 922 F.2d at 620.

Defendant was illegally stopped, but an outstanding warrant was found and he was arrested on that, and that supported the search of the car and attenuated the illegal stop. Hudson v. Michigan on applicability of the exclusionary rule supports this conclusion. State v. Grayson, 2010 Mo. App. LEXIS 586 (May 11, 2010)

We believe the principle set forth in Hudson has application here. Defendant’s Fourth Amendment right to be free from unreasonable seizure was violated when he was stopped and detained without a reasonable, articulable suspicion that he was engaged in criminal activity. However, the methamphetamine evidence found on Defendant’s person and in Officer Lambert’s police cruiser was not found because of the invalid stop. Instead, this evidence was found after a search incident to Defendant’s arrest on a valid warrant. The existence of that outstanding arrest warrant meant that Defendant could be seized and arrested at any time by any law enforcement officer. To our knowledge, an absence of reasonable, articulable suspicion necessary to support a Terry stop has never protected a person from being seized based on a valid arrest warrant.

[I don’t think so. Saying it doesn’t make it so, Missouri. This case ignores the “but for” standard, and essentially likens it (without saying so, because that would be even more intellectually dishonest) to abandonment in flight from an illegal stop. So, an illegal stop is cured by finding evidence of crime, whether the defendant discards the drugs before arrest or after? I’m stunned.]

Defendant’s parole search was based on reasonable suspicion that defendant had missed parole meetings. The PO saw defendant driving his car, so he went to the house, and saw the car. Defendant would not answer the door, so the PO called for police backup. State v. Benavidez, 2010 NMCA 35, 148 N.M. 190, 231 P.3d 1132 (2010), Certiorari Denied, March 24, 2010, No. 32,254.*

Defendant was present when the search warrant was executed and he was handcuffed. Fifteen minutes into the search, he was searched too. The search warrant was diligently being pursued, and the search of his person was not unreasonable because of the length of the detention. State v. Winton, 2010 NMCA 20, 148 N.M. 75, 229 P.3d 1247 (November 18, 2009), certiorari denied, 2010 147 N.M. 673, 227 P.3d 1055 (2010).

Defendant was seen fumbling around in his car when stopped, and the officer got him out. His belt was undone and his shirttail was protruding through the fly. The officer had reasonable suspicion, and he was justified in looking where the shirttail was coming from. State v. Williams, 2010 NMCA 30, 148 N.M. 160, 231 P.3d 616 (2010), certiorari granted, April 1, 2010, No. 32,263.

Defense counsel was not ineffective for not challenging the officer’s entry into the property in response to a 911 call for help. State v. Pierce, 155 Wn. App. 701 (2010).*

Defendant was indicted for a two year old murder, and police obtained a search warrant for the weapon and clothing potentially worn during the murder, as well as possible communications between defendant and co-conspirators. Even though the defendant moved between the murder and the search warrant, it was reasonable for the magistrate to conclude that the evidence would still be retained at defendant’s new address. Under the Tenth Circuit’s rule (United States v. Gonzales, 399 F.3d 1225 (10th Cir. 2005)), the question of probable cause does not have to even be addressed if the good faith exception would apply, and it does here. United States v. Birch, 401 Fed. Appx. 351 (10th Cir. 2010) (unpublished). [I’ve always disagreed with this approach to the GFE exception because it is judicial laziness to avoid deciding probable cause and it tends to stop development of the Fourth Amendment. Besides, Gates makes it so easy for judges to not have to think in the first place. So why not decide probable cause?]

Nobody had standing to challenge the stop of the car in this identity theft case. The driver did not know who owned it, and he could not even show how he was in possession of it. The others weren’t even in it. As to a search of a motel room and a house, only one defendant had standing as to them because nobody else claimed to be a guest there. As to the motel room, the government’s claim of protective sweep fails because it must be incident to arrest, and it wasn’t. However, the government did show that the search was by consent by a person with apparent authority. United States v. Poghosyan, 2010 U.S. Dist. LEXIS 117271 (D. Kan. October 28, 2010).*

Oklahoma tax assessor cannot enter home for purposes of valuing real property. Atkinson v. Gurich, 2011 OK 12, 248 P.3d 356 (2011):

[*P1] The issue presented is whether the trial court abused its discretion in ruling that the county assessor can enter the home of a taxpayer who challenged the assessor’s fair market value assessment. The fourth amendment of the United States Constitution, and art. 2 § 30 of the Okla. Const., protect the right of the people to be secure in their houses and effects against unreasonable searches. These protections are incorporated into 68 O.S. 2001 §2818 (C)(1) and (D) which prohibit the county assessor from entering the home of a taxpayer, unless the taxpayer requests a visual inspection of household personal property because its value is disputed. Because Oklahoma County no longer taxes household personal property there is neither a reason nor a right allowing the assessor to enter residential property. Accordingly, we hold that: 1) in the absence of a dispute over the valuation of household personal property and a request by the taxpayer, 68 O.S. 2001 § 2818(C)(1) and (D) do not authorize the County Assessor to enter residential property; and 2) 12 O.S. Supp. 2008 § 3234(A)(2) of the Oklahoma Discovery Code does not provide an exception when entry to residential property is otherwise explicitly precluded by statute.

. . .

[*P9] This cause concerns a dispute over the valuation of fair market value, the taxable market value, and the gross assessed value, not a valuation of household personal property. No other statute, and neither the Oklahoma constitution nor the United States Constitution allow such governmental intrusion. Here, there is no dispute over household personal property and Oklahoma County does not collect taxes on household personal property.

[*P10] Instead, fair market valuation of residential property is conducted pursuant to 68 O.S. 2001 § 2829 which sets forth the mass appraisal methodology as a process which uses known information about the property’s characteristics such as location, use, size, sales price and other information from similar properties. The county assessor is required to physically visit the property every four years and, by the assessor’s own admission, private residences are not entered during the valuation process. There is no information to be gained by entering the taxpayer’s home that is necessary for a fair market valuation. Even if the inside of the taxpayer’s home is lavish it is likely that the home would just be over-built for the area and the taxpayer would have invested more into the home than its fair market value.

The reliability of the CI for defendant’ stop was virtually admitted at the suppression hearing, so defendant did not preserve the issue for appeal. The 15-20 minute wait for a drug dog was not unreasonable under the totality of the information that the officers had. State v. Martinez, 2010 NMCA 51, 233 N.M. 262, 233 P.3d 791 (2010), Certiorari Denied, May 5, 2010, No. 32,318.*

The District Court’s decision is supported by the record. “Further, although a surveillance video on the police car does not clearly show that Gonzalez’s truck crossed the fog line, it does not contradict Dunn’s testimony that the truck did cross the fog line.” United States v. Gonzalez, 383 Fed. Appx. 933 (11th Cir. 2010) (unpublished).*

Defendant’s counsel’s alleged failure to investigate witnesses in NYC would not have changed the outcome of what it was pertinent to, so no IAC. State v. Blake, 2010 Del. Super. LEXIS 255 (May 27, 2010).*

911 call about a gunshot at a park led to officers approaching defendant’s parked car, and they got the defendant out at gun point. He was patted down for a weapon, and it was apparent that all he had in his pocket was a glass pipe. The seizure of the glass pipe was unreasonable. State v. Johnson, 2010 NMCA 45, 233 N.M. 237, 233 P.3d 371 (2010).

Consent to enter mooted the question of the Fourth Amendment legality of the entry on an arrest warrant for the right person with the same name but the wrong identifiers. The search warrant issued thereafter was valid. United States v. Hinojosa, 606 F.3d 875 (6th Cir. 2010)* (“See, e.g., United States v. Pasquarille, 20 F.3d 682, 685 (6th Cir. 1994) (‘[A] denial of a motion to suppress will be affirmed on appeal if the district court’s conclusion can be justified for any reason.’).”

Defendant’s stop was justified under community caretaking function when the officer encountered defendant and another walking away from the area of gunshots and a possible stabbing. Defendant was holding his stomach, and the officer objectively believed he was a victim. Moore v. State, 997 A.2d 656 (Del. 2010).*

State knock and announce rule was violated where officers knocked for 10-12 seconds on the door of a house at 10 p.m. The house was large enough that nobody inside could get to the door in 10-12 seconds, and the officers never considered the size of the house; they just followed their customary practice. Motion to suppress granted because the failure to consider how long it would take an occupant to get to the door at night was a violation of the state constitution. State v. Ulibarri, 2010 NMCA 84, 148 N.M. 576, 240 P.3d 1050 (2010), cert. denied, 148 N.M. 942, 242 P.3d 1288 (2010):

P18 In our view, the present case is distinguishable from Hand and Johnson. Here the warrant was executed at roughly 10:00 p.m. The Home is not small like a motel room or a trailer; it is a house with two entrances and separate rooms. It was understood that Defendant and the other suspects were not in the home when the search warrant was executed and that Defendant resided with Mr. Roybal. Accordingly, we conclude that the ten- to twelve-second period of silence which followed the knock and announce in the present matter cannot be measured in the same context as was the period of silence which followed the knock and announce in Hand and Johnson. Therefore, the fact that a ten-second waiting period was deemed reasonable in those cases is not determinative here.

P19 In our view, an objectively reasonable officer would consider the time at which the search warrant is executed, the identity of the occupants likely to be within the dwelling at the time of the search, and the size of the dwelling to be searched in assessing whether a period of nonresponsiveness following a knock and announce signals constructive refusal. No evidence was presented that the officers considered any of these facts. Rather, the findings indicate that the officers relied on the ten to twelve seconds of silence following the knock and announce, in and of itself, as the basis for their conclusion that they had been constructively refused admittance. Indeed, the lead officer testified that forcing entry after waiting ten seconds following a knock and announce is a “customary” practice. Such a practice not only violates a clear tenet of our case law that there are no bright line rules as to how long an officer must wait before inferring constructive refusal but, in this case, caused exactly the type of harms the knock-and-announce rule is designed to prevent: Roybal’s home was needlessly damaged; Roybal was unnecessarily injured; and the limited duration of time between the knock and announce and forced entry interfered with Roybal’s attempts to comply with the officers’ requests for admission.

Clearly a product of Hudson v. Michigan …

Defendant was seen around an apartment complex, and officers knew that there was an arrest warrant for him. They had their “eye out” for him. He was seen, the officer called out to him, and he fled into an apartment. It was determined that the apartment was not his, and there was no discernable connection to him and the apartment. Officers banged on the door for him to come out, and they finally got “I’m coming,” but he didn’t come out. They were afraid he was arming himself or was destroying evidence, so they secured a ballistic shield and broke in. Defendant was found hiding inside, and a protective sweep was done. Marijuana was found in plain view 5′ from defendant’s point of arrest. Nobody would consent to a search so a search warrant was obtained for the apartment. The entry was valid. United States v. Willis, 2010 U.S. Dist. LEXIS 103223 (E.D. Mich. September 29, 2010).*

Defendant’s tractor trailer seen in a truck stop was unregistered and appeared overweight. This justified a stop when the truck pulled out. The officer developed reasonable suspicion that the truck had drugs in it from various factors, including the fact the truck was off route and passed up several places to refuel to do so farther from the highway to be less noticeable. Defendant consented to a search of the trailer. United States v. Mungia, 743 F. Supp. 2d 694 (E.D. Mich. 2010).*

Defendant’s motion to suppress cellular telephone site location information produced by administrative subpoena without a showing of probable cause is moot because the government is not going to rely on the information. The government’s claims that the cell provider conducted a private search or that inevitable discovery would somehow validate it were rejected. The cell provider should not have given the information, but it did, but the government’s disclaimer of the evidence leaves defendant with only a possible civil remedy against the cell phone provider. United States v. Redd, 2010 U.S. Dist. LEXIS 103385 (D. Kan. September 29, 2010).*

Once the defendant files his company for bankruptcy, he loses any reasonable expectation of privacy in the records of the business to the trustee who can then consent to search. United States v. Pavlock, 2010 U.S. Dist. LEXIS 120767 (N.D. W.Va. October 26, 2010).*

Defendant had a package shipped to him with drugs in it, and the bus company opened it. They called the police, and the officer opened the package, too, and the search was invalid because the officer’s search exceeded the private search. State v. Rivera, 2010 NMSC 46, 148 N.M. 659, 241 P.3d 1099 (2010), revg State v. Rivera, 2009 NMCA 49, 146 N.M. 194, 207 P.3d 1171 (Ct. App. 2009).

Officers found out about a warrant on defendant, and he was arrested on that warrant and subjected to a search incident that produced marijuana. The search incident was valid, and the trial court erred in suppressing. State v. Edwards, 307 Ga. App. 267, 704 S.E.2d 816 (2010).*

Katherine J. Strandburg, Home, Home on the Web and Other Fourth Amendment Implications of Technosocial Change, 70 Md. L. Rev. 101 (2011). Abstract on SSRN:

The rapidly changing social role of the Internet and other digital media requires a rethinking of the scope of Fourth Amendment protection. The social role of the Internet and related technologies goes far beyond serving as a new means of communication, analogous to the telephone and postal mail. To preserve Fourth Amendment protections in the face of changing technology, courts must focus not only on the potential for increasing intrusion into time-honored private realms, as the Supreme Court did in Kyllo, but also on the privacy implications of technology-mediated social change that were recognized in Katz. First, courts should recognize that an aggressive form of third party doctrine suggesting that any exposure of private data to an intermediary destroys reasonable expectations of privacy is inconsistent with Fourth Amendment doctrine relating to shared social spaces. Second, courts should adopt an approach of technosocial continuity, acknowledging both the increasing intrusiveness that technology makes possible and the intertwined and changing social structure of the physical and digital worlds. Viewed from a technosocial perspective, much cloud computing is an extension of the home or office. Similarly, social networking platforms sometimes serve as technosocial extensions of the home, connecting people with their friends, families, and intimates and aggregating the varied pieces of private life in ways that mirror the home’s valued social role. To maintain technosocial continuity with Fourth Amendment protection of traditional bastions of privacy, such as the home, courts should zoom out from a focus on translating the Fourth Amendment’s protections to cyberspace and see digitally-mediated social behavior for what it frequently is–an inextricable part of social and private life. To maintain a space for private life away from government scrutiny, the Fourth Amendment’s protections must reflect the technosocial reality of citizens’ private lives.

On Law.com: Courts Struggle With Police Searches of Smartphones by Joshua Engel:

In most states, police can arrest people for minor offenses, including traffic offenses punishable only by a fine. In 2001, the U.S. Supreme Court upheld the ability of police in Texas to arrest a woman for failure to wear a seat belt after she was stopped while driving her two children home from soccer practice. Atwater v. Lago Vista, 532 U.S. 318 (2001).

In the Atwater case, the woman was handcuffed and driven to the police station where she was booked and photographed. Her car was inventoried and towed. She ended up paying a $50 fine. Had the arrest in the Texas case happened today, the police could also likely have searched through her cell phone. This means, if she had a smartphone such as iPhone or Android, the police could search through all of her text messages, photos, calendar entries, and e-mails. In other words, much of her personal life would be exposed to the police as a result of her failing to wear a seatbelt.

A dog alert on cash is meaningless, and it does not support seizure of the money. Harris v. City of Mayfield Heights, 2011 Ohio 1943, 2011 Ohio App. LEXIS 1652 (8th Dist. April 21, 2011):

[*P19] We find the appellees’ reliance on the drug dog’s positive hit on Harris’s currency insufficient to support an inference of criminal activity. In United States v. $5,000 in U.S. Currency (C.A.6, 1994), 40 F.3d 846, the court addressed the unreliability of using narcotics-trained dogs in drug cases. The court relied on studies showing that most currency in this country is tainted with traces of narcotics. Id. The court found “the evidentiary value of the narcotics dog’s alert to be minimal.” Id. at 849. The court reversed the order of forfeiture because there was little other evidence to connect the currency to drug activity. Id. at 850; See United States v. $53,082.00 in United States Currency (C.A.6, 1993), 985 F.2d 245, 250, citing United States v. $80,760.00 in United States Currency (N.D.Texas 1991), 781 F.Supp. 462, 475, fn. 32 (“There is some indication that residue from narcotics contaminates as much as 96% of the currency currently in circulation.”); see, also, $5,000 in United States Currency at 849; United States v. Carr (C.A. 3, 1994), 25 F.3d 1194; United States v. $639,558.00 in United States Currency (C.A. D.C. 1992), 955 F.2d 712, 714, 293 U.S. App. D.C. 384.

[*P20] In Six Hundred Thirty-Nine Thousand Five Hundred and Fifty-Eight Dollars ($639,558) in United States Currency, the court cited the testimony of an expert, Dr. James Woodford, who testified that 90% of all cash in the United States contains sufficient quantities of cocaine to alert a trained dog. The court also noted that there was at least one study indicating that up to 97% of all bills in circulation are contaminated by cocaine, with an average of 7.3 micrograms of cocaine per bill. Crime and Chemical Analysis 243 SCIENCE 1554 (1989). Id. At a footnote, the court wrote:

[*P21] “Why the nation’s currency is so thoroughly corrupted has been a topic of inquiry. It has been estimated that one out of every three circulating bills has been involved in a cocaine transaction. R. Siegel, Intoxication 293 (1989). Cocaine attaches —in a variety of ways — to the bills, which in turn contaminate others as they pass through cash registers, cash drawers, and counting machines at banks and commercial establishments, id.; Crime and Chemical Analysis, supra note 2, at 1555; Tr. I at 28. Dr. Woodford testified that, as a result, bills may contain as little as a millionth of a gram of cocaine, but that is many times more cocaine than is needed for a dog to alert. Officer Beard related that 10 percent of the alerts he had witnessed were to cash alone, a phenomenon we have encountered before. United States v. Trayer, 898 F.2d 805, 808-09, 283 U.S. App. D.C. 208 & n. 3 (D.C.Cir. 1990). See generally Taslitz, Does the Cold Nose Know? The Unscientific Myth of the Dog Scent Lineup, 42 Hastings L.J. 15, 29 & n. 71 (1990). If the information related above proves accurate, a court considering whether a dog sniff provides probable cause, see generally United States v. Colyer, 878 F.2d 469, 471, 278 U.S. App. D.C. 367 & n. 2, 483 (D.C.Cir. 1989), may have to take into account the possibility that the dog signaled only the presence of money, not drugs.” Id. at fn 2.

[*P22] Here, similar to the federal cases cited above, the city of Mayfield Heights had no evidence, other than the positive drug sniff of the narcotics dog, that the money found on Harris was related to drug activity. …

WaPo: Lawmaker wants DNA from suspects when arrested for state crimes by Rob Hotakainen:

In 2001, King County Sheriff Dave Reichert relied on a DNA match to solve the case of Washington state’s Green River Killer, who murdered 49 women and ranks as the nation’s most prolific serial killer.

Now a Republican congressman, Reichert wants Congress to expand the use of DNA testing by getting more states to collect DNA samples, just as they do fingerprints, when suspected felons are arrested for state crimes.

Such testing already is allowed for anyone arrested by a U.S. law enforcement agency for a federal crime.

So much for Republicans and “big government” intruding into our lives.

On Network World: Michigan State Police reply to ACLU about cell phone data extraction devices:

The Michigan State Police do not seem to appreciate the publicity raining down on it over Fourth Amendment rights and its use of Universal Forensic Extraction Devices (UFED) which can extract data off 95% of cell phones on the market. The ACLU was quoted a half million dollars as the cost of documents associated with a FOIA request. I reported on it last week as State Police can suck data out of cell phones in under two minutes. The MSP issued the following statement: …

The Michigan State Police denies that they have done anything illegal with the UFEDs, using them only with warrants or consent.

More on the Michigan State Police and surreptitiously copying cell phone data on Jonathan Turley’s blog yesterday: iPhone and Android Tracking You for Apple and Google by David Drumm.

There have been at least 20 articles and blog posts I’ve seen since this story broke.

Because the stop of the defendant was unlawful, his “new crime” of alleged disorderly conduct during the unlawful patdown was not an intervening circumstance. United States v. Olavarria, 2011 U.S. Dist. LEXIS 42867 (S.D. N.Y. April 20, 2011):

Here, the Government — which bears the burden of demonstrating that Olavarria committed a “new crime” that attenuated the effects of the illegal traffic stop, see Brown, 422 U.S. at 604 — has not offered evidence that the alleged five-minute altercation between the defendant and the police officers became “‘a potential or immediate public problem.’” Weaver, 16 N.Y.3d at 127-28 (quoting Munafo, 50 N.Y.2d at 331). While the encounter took place on a public street in the Bronx at about 6:00 p.m., the fact that this incident occurred in a public place is, standing alone, insufficient to bring it within the purview of the disorderly conduct statute. …

The Government has offered no evidence that any member of the public observed the incident, that anyone was in the vicinity of the traffic stop, or that the dispute extended beyond Olavarria and the officers. Given that the entire incident took no more than five minutes, it is unlikely that Olavarria’s conduct attracted notice or presented any risk of obstructing vehicular or pedestrian traffic. While one officer testified that Olavarria broke away from the officers and “headed towards the middle of the street” before falling to the ground with several officers, the two other police witnesses — including Detective Dunsing, Olavarria’s principal antagonist — had no such recollection. …

Because the firearm was seized from the car, it did not violate the Fourth Amendment to not list it on the inventory form. United States v. Peterson, 2011 U.S. Dist. LEXIS 42174 (N.D. Tex. April 19, 2011).*

There was a consent form signed in this case, but there is enough factual dispute to require a hearing. United States v. Younis, 2011 U.S. Dist. LEXIS 42281 (S.D. N.Y. April 19, 2011).*

While shotgun shells are not weapons in themselves, finding them during a patdown justified going into the pockets to get them out. Defendant showed a causal connection between the seizure of his car keys and an admission that there was a shotgun in the trunk, so the gun is suppressed. United States v. Teague, 2010 U.S. Dist. LEXIS 142717 (N.D. Ga. November 22, 2010).*

The “public safety exception” permitted officers to enter the bedroom in which defendant was hiding as the police were looking for him for armed robbery. United States v. Holland, 2011 U.S. Dist. LEXIS 42708 (N.D. Ohio April 20, 2011).*

NYTimes editorial on computer searches: Shielding the Privacies of Life:

The Supreme Court has never heard a case challenging the government’s authority to search a computer. It is time, after a panel of the United States Court of Appeals for the Ninth Circuit opened the way last month to vast government intrusion. It ruled that, without good reason to suspect evidence of a crime, border agents could seize a laptop and open a dragnet search of files, e-mails and Web sites visited.