U.S. v. Huart

In prosecution on possession of child pornography charge, Dist. Ct. did not err in denying defendant’s motion to suppress pictures contained in defendant’s cell phone, where police had seized cell phone while defendant was at halfway house serving remainder portion of sentence on prior child pornography possession conviction. Rules of halfway house precluded defendant from having cell phone, and for other residents who had permission to possess cell phone, staff at halfway house had ability to view contents of resident’s cell phone at any time. As such, defendant had no reasonable expectation of privacy in his seized cell phone or its contents.