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I would hope that this "reasonable expectation of privacy" would apply to any private communication, regardless of the form. I would hope it would apply to locational tracking as well. We do have the right to not answer "where were you on the night of...". Just because an electronic device that we are carrying can answer that, it doesn't mean the authorities have any right to that. Not the one owned by the "suspect", anyway, as that would be self incrimination. Like the old days, witness reports on where one was, surveillance video, credit card transactions, etc. - sure. They are arguably "third party" accounts of one's whereabouts. One's cell phone is, to me, akin to self incrimination and should be disallowed.
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Jeff
'72 911T 3.0 MFI
'93 Ducati 900 Super Sport
"God invented whiskey so the Irish wouldn't rule the world"
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