High Tech Squares Off with the Fourth Amendment, Round 4: Should the Government be Able to Search and Hold Your Laptop at the Border without a Warrant?

There used to be a day when (for the otherwise law-abiding) a messed with suitcase was the worst thing you were likely to encounter on a pass through Customs into United States. Sadly, this is no longer the case.

The federal United States Customs and Border Protection agency is part of the Department of Homeland Security. We live in a perilous world and there are pressing security concerns at our nation’s borders.

But how should security priorities, albeit valid ones, interact with the array of electronic devices that seemingly all travelers now carry as a matter of routine? A quick and unscientific survey at LAX over the recent Thanksgiving weekend yielded an almost uncountable number of laptops, tablets, telephones, and other depositories of electronic information, of varying makes, sizes and capabilities.

It is a fair assumption that much of the information imprinted in or accessible by these devices is uniquely personal to the holder or is business related and that much of it could not be seized or examined by the government, other than through the traditional tools of warrant, subpoena or summons.

That is, of course, assuming that the possessor of this information is standing inside the United States. But if one is outside, seeking leave to get in, then it is a very different story. Traditionally, the government’s right to search and examine at the border has been far broader and more expansive than “intra-country” searches. Customs officials freely inspect bags, packages and persons. All of this conduct occurs without a warrant and it has always been thus.

The question is: how far can this latitude extend to personal electronic technology and the wealth of data it holds? These limitations are being litigated in various trial courts, as reflected in a story in The New York Times, dated December 4, 2012.

It is the government’s position that in a border search of an electronic device, that Customs officers can keep the device in question for “a reasonable amount of time” and have the right to access all information contained therein, either voluntarily through a password provided by the owner or involuntarily, by other means. No warrant is needed.

It is also estimated that approximately 5,000 such electronic searches occur every year. The “who”, “what”, “when” and “why” of these searches are wholly Customs-discretionary.

But this may change as the cases, now pending, make their way through the courts. A decision is expected soon in the case of Pascal Abidor, an Islamic scholar who was detained as he tried to enter the country from Canada via Amtrak. His laptop searched and held for 11 hours.

In another case, venued in federal court in Minnesota, the government confiscated a laptop, camera and USB drive from a member of a group supportive of the Wikileaks organization and held them for seven weeks. The owner is suing and the judge has denied the government’s motion to dismiss, holding (at least initially), that the traditional latitude afforded the government in border searches does not completely trump the Constitution.

If in fact, it is found in one or both of these cases, that the government is using its border search power to target certain kinds of political speech (as is alleged), then some kind of limitation might be on the horizon. Given the enormous amount of data people now casually travel with in their pockets or briefcases, some limit may well be overdue.

High Tech Squares Off with the Fourth Amendment, Round Three: The Pittsburgh “Moocherhunter” Case

Have you ever “borrowed” access to someone else’s Wi-Fi network? Industry estimates are that up to 32% of people who use computers have tried to get on a wireless network that was not theirs, at one time or another. In and of itself, this is a minor infraction, more a commentary on the general decline of civility and good manners in our society than anything else.

Yet, in the case of a defendant named Richard Stanley, his choice to use someone else’s Wi-Fi without permission has given rise to an interesting series of Fourth Amendment legal issues as his prosecution for possession of child pornography proceeds forward in federal court in Pittsburgh.

Continue reading “High Tech Squares Off with the Fourth Amendment, Round Three: The Pittsburgh “Moocherhunter” Case”

High Tech Squares Off with the Fourth Amendment, Round Two: The Aurora, Colorado GPS Case

As the surveillance technology at the disposal of state and federal law enforcement continues to evolve in both sophistication and availability, inevitably there is going to be friction between the use of this technology and constitutional limitations. This tension is already being played out in trial courts across the country. It is an unfolding story well worth monitoring.

A current example is the on-going prosecution of an alleged bank robber named Christian Paetsch in federal court in Colorado, as related in an article in The New York Times, dated November 20, 2012.

Continue reading “High Tech Squares Off with the Fourth Amendment, Round Two: The Aurora, Colorado GPS Case”

Should the Government be Allowed to Take DNA Samples After an Arrest, but Prior to a Conviction? High Tech Squares Off with the Fourth Amendment as the Supreme Court Grants Certiorari in King v. Maryland

DNA evidence has come a long way since the O.J. Simpson case. It has infiltrated the popular consciousness through television shows like “CSI” and others. The awesome power of this technology to condemn, but also to frequently exonerate, is par for the course now, recognized and accepted by judges, juries and practitioners as a reality of the criminal justice system landscape.

Many states, prudently, have codified their methods for the collection and utilization of such evidence. Maryland is one of them, having enacted the “Maryland DNA Collection Act”, Md. Code Ann., Pub. Safety Section 2-504.

Continue reading “Should the Government be Allowed to Take DNA Samples After an Arrest, but Prior to a Conviction? High Tech Squares Off with the Fourth Amendment as the Supreme Court Grants Certiorari in King v. Maryland”

The Supreme Court Speaks and a Clarified Area of the Law…Becomes a Little Less Clear: The Constitution’s Confrontation Clause and Williams v. Illinois

From a defense viewpoint, one of the highlights of Supreme Court jurisprudence over the last decade or so has been a trio of cases dealing with a defendant’s Sixth Amendment right to confront the witnesses against him (or her).

In the three cases, Crawford v. Washington, Melendez-Diaz v. Massachusetts and Bullcoming v. New Mexico, the Court imposed and maintained stringent limits on a prosecutor’s ability to admit forensic-type evidence while circumventing the Sixth Amendment’s Confrontation Clause right to cross-examine. The actual evidence at issue in each of the three cases was different: Crawford (a tape recording), Melendez-Diaz (a state forensic laboratory report) and Bullcoming (a blood alcohol report).

Continue reading “The Supreme Court Speaks and a Clarified Area of the Law…Becomes a Little Less Clear: The Constitution’s Confrontation Clause and Williams v. Illinois”

Serious Fraud Office Issues Tougher Revised UK Bribery Act Policies

In a development which took some by surprise, on 9 October 2012, the UK’s Serious Fraud Office (SFO) issued new policies under the Bribery Act 2010, which could change the way some companies do business. The SFO is the UK independent government agency that investigates and prosecutes serious or complex fraud, as well as corruption. Its powers are similar in some respects to those of the U.S. Securities and Exchange Commission and U.S. Department of Justice. The new policies are related to facilitation payments, business expenditure (hospitality) and corporate self-reporting. The announcement is meant to revise existing SFO pronouncements on the enforcement of the Bribery Act 2010, which took effect on 1 July 2011. Given the new Act’s tough penalties and the apparent ambiguity surrounding the consequences of self-disclosure, businesses may want to take extra care to comply with its provisions. Accordingly, businesses should consider seeking the advice of legal counsel in navigating this statute and its attendant revisions.

Click here to read more.

The Second Circuit Reverses High Profile Convictions over “Preventable” Brady Error: More Grist for Those Who Favor Reform

This past month, the United States Court of Appeals for the Second Circuit overturned the convictions of six brokers and traders who were charged and later convicted in an insider trading scheme in which day traders were allowed to eavesdrop on confidential communications via broker “squawk boxes.” A primary basis for the appeal court’s ruling was the failure of federal prosecutors to produce as “Brady” material transcripts of depositions taken by an attorney for the Securities and Exchange Commission in a related matter. * Portions of these withheld transcripts contradicted the testimony of key government witnesses at trial, hence triggering the reversal.

Continue reading “The Second Circuit Reverses High Profile Convictions over “Preventable” Brady Error: More Grist for Those Who Favor Reform”

You Can be Indicted for Deleting Text Messages

The United States Department of Justice recently charged Kurt Mix, a former engineer for BP with two counts of obstruction of justice. According to the criminal complaint and arrest warrant, Mix worked on BP’s attempt to estimate the amount of oil leaking from the Deepwater Horizon blowout. He was also involved in efforts to stop the leak. According to the complaint, Mix, received numerous notices instructing him to retain all information related to Deepwater Horizon. These notices instructed Mix to retain ESI, including text messages. After receiving these notices, Mix allegedly deleted over 200 text messages with a BP supervisor which Mix had on his iPhone which contradicted BP’s public statements related to the flow rate of oil from the leaking well. In addition, Mix, allegedly deleted more than 100 text messages with a BP contractor from his iPhone after he learned his iPhone was about to be imaged. According to the complaint, Mix deleted these messages after receiving numerous legal hold notices and while he was in contact with defense counsel. If convicted, Mix faces up to 20 years in prison and a $250,000 fine per count. This criminal complaint demonstrates the serious nature of a person’s obligations to retain ESI when an investigation is pending at that all ESI, including text messages, fails within the rubric of what must be retained.

Go on the Offense with the FCPA

Most companies fear the FCPA and the harm it will do to their companies.  In a recent article published for the Asian-Mena Counsel, I offer a modest proposal – go on the offense with the FCPA and reap millions in potential increased enterprise value.

Here is the secret:  if your company sees a potential exit strategy in the near future and you operate in certain regions of the world, you could command, and US suitors would be willing to pay, a premium for your company, into the millions, provided that you have meaningful a FCPA compliance regime.  Make a strategic move to make your company FCPA compliant and reap the rewards.

For a more detailed review, please see:
http://www.duanemorris.com/articles/static/wolfe_gehring_asiamena_0512.pdf

Does Brady v. Maryland Need a New Look? A Bi-Partisan Panel Weighs in with a Proposal to Reform Federal Criminal Discovery.

We all read Brady v. Maryland, 373 U.S. 83 (1963) in law school. At least, it was assigned. It remains a pillar of federal procedure; a transformative Warren Court opinion and a reminder of an era in which the expansion and definition of the rights of criminal defendants seemingly was the order of the day.

For those readers who either do not have a law degree or did not follow their 1L syllabus, Brady concerns the obligation of the prosecution to disclose material exculpatory information to the defense in advance of a criminal trial.

Continue reading “Does Brady v. Maryland Need a New Look? A Bi-Partisan Panel Weighs in with a Proposal to Reform Federal Criminal Discovery.”

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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