PA: No REP in data moving back and forth over a (nearly) public wifi connection where user agreement told users that

Defendant connected to the wifi at his college, and he was aware of the computing access policy that said that he had no Fourth Amendment reasonable expectation of privacy in the information that moved back and forth over his connection. “These acts by appellant provide clear intent to relinquish any purported expectation of privacy in the WiFi connection records. Furthermore, this abandonment by appellant was voluntary.” Commonwealth v. Dunkins, 2021 Pa. LEXIS 3994 (Nov. 17, 2021).

The state’s acquisition by a court order (“the functional equivalent of a warrant”) based on probable cause for 108 days of defendant’s CSLI was reasonable and complied with Carpenter, albeit nearly three years before Carpenter. There was an individualized showing of probable cause and nexus for this CSLI. The lack of any geographical limitation did not violate the particularity requirement. Commonwealth v. Pacheco, 2021 Pa. LEXIS 3999 (Nov. 17, 2021)