U.S. v. Caira

In prosecution on drug charges stemming from govt. investigation of website that sold sassafras oil, which formed component of illegal drug known as ecstasy, Dist. Ct. did not err in denying defendant’s motion to suppress evidence obtained via administrative subpoena from Microsoft regarding defendant's Hotmail account, which included defendant’s name and I.P. address that linked defendant’s activities to said website. Although government did not obtain warrant prior to issuing administrative subpoena, no “search” for purposes of 4^th Amendment occurred, since, under “third-party” doctrine, defendant had no expectation of privacy in his I.P. address when he shared same with Microsoft, and where his I.P. address is transmitted during his use of Internet.