TX3: REP in car parked on curtilage; plain view suppressed

The trial court’s suppression order is affirmed. Defendant had a reasonable expectation of privacy in his curtilage and his car parked there. The plain view inside his car and then the search was unreasonable. State v. Serna, 2021 Tex. App. LEXIS 9302 (Tex. App. – Austin Nov. 17, 2021).

In an FLSA overtime case, the employer “‘did not have any reasonable expectation of privacy in areas of [his office] where the public was invited to enter and to transact business.’ Maryland v. Macon, 472 U.S. 463, 469 (1985). Therefore, the officers did not violate the Fourth Amendment when they walked into the public entrance of Lovett’s clinic.” United States Dep’t of Labor v. Lovett, 2021 U.S. App. LEXIS 33883 (11th Cir. Nov. 16, 2021).

Disclosure of national security letters denied. The court assumes that the government has otherwise complied with Brady and other constitutional limitations unless the contrary has been shown. United States v. Chaoqun, 2021 U.S. Dist. LEXIS 220982 (N.D.Ill. Nov. 16, 2021).

The warrant papers remain sealed for one year. A person with interest can apply for unsealing. In re Seized United States Currency, 2021 U.S. Dist. LEXIS 221120 (D.S.C. Nov. 15, 2021).

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