private affairs inquiry in Washington

2015State v. Puapuaga, 164 Wn.2d 515, 522 , 192 P.3d 360 (2008). ¶30 The private affairs inquiry protects only those privacy interests that Washington citizens have held, and should be entitled to hold, safe from governmental trespass absent a warrant.

2011Puapuaga, 164 Wash.2d at 522 , 192 P.3d 360 . ¶ 11 Here, the private affairs inquiry focuses on a jail visitor's asserted privacy interest in her driver's licensing information contained in a state government database that a law enforcement officer accessed.

2015State v. Puapuaga, 164 Wn.2d 515, 522 , 192 P.3d 360 (2008). ¶30 The private affairs inquiry protects only those privacy interests that Washington citizens have held, and should be entitled to hold, safe from governmental trespass absent a warrant.

2011Puapuaga, 164 Wash.2d at 522 , 192 P.3d 360 . ¶ 11 Here, the private affairs inquiry focuses on a jail visitor's asserted privacy interest in her driver's licensing information contained in a state government database that a law enforcement officer accessed.

2008Surge, 160 Wn.2d at 71 . ¶11 The private affairs inquiry focuses on those privacy interests that Washington citizens have held and should be entitled to hold safe from governmental trespass absent a warrant.

2008Surge, 160 Wn.2d at 72 . ¶12 Here, the private affairs inquiry focuses on a pretrial detainee’s asserted privacy interest in their personal effects, not on the privacy interest of the ordinary citizen.

2016In determining whether something is a private affair (meaning “those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant f Myrick, 102 Wn.2d at 511 ), we consider both “the nature and extent of the information which may be obtained as a result of the governmental conduct” and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d 121, 126 , 156 P.3d 893 (2007). 2 A. Cell phones ma

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2016In determining whether something is a private affair (meaning “those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant f Myrick, 102 Wn.2d at 511 ), we consider both “the nature and extent of the information which may be obtained as a result of the governmental conduct” and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d 121, 126 , 156 P.3d 893 (2007). 2 A. Cell phones ma

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2016In determining whether something is a private affair (meaning “those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant f Myrick, 102 Wn.2d at 511 ), we consider both “the nature and extent of the information which may be obtained as a result of the governmental conduct” and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d 121, 126 , 156 P.3d 893 (2007). 2 A. Cell phones ma

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2016In determining whether something is a private affair (meaning “those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant f Myrick, 102 Wn.2d at 511 ), we consider both “the nature and extent of the information which may be obtained as a result of the governmental conduct” and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d 121, 126 , 156 P.3d 893 (2007). 2 A. Cell phones ma

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2016In determining whether something is a private affair (meaning "those privacy interests which citizens of this state have held, and should be entitled to hold, safe from government trespass absent a warrant," see Myrick, 102 Wn.2d at 511 ), we consider both "the nature and extent of the information which may be obtained as a result of the governmental conduct" 5 State v. Samalia (Adrian Sutlej), No. 91532-6 and the historical protection afforded to the interest asserted. 1 State v. Miles, 160 Wn.2d 236, 244 , 156 P.3d 864 (2007); see also Hinton, 179 Wn.2d at 868-69 ; State v. Jorden, 160 Wn.2d

2008Surge, 160 Wash.2d at 71 , 156 P.3d 208 . ¶ 11 The private affairs inquiry focuses on those privacy interests that Washington citizens have held and should be entitled to hold safe from governmental trespass absent a warrant.

2008Surge, 160 Wash.2d at 72 , 156 P.3d 208 . ¶ 12 Here, the private affairs inquiry focuses on a pretrial detainee's asserted privacy interest in their personal effects, not on the privacy interest of the ordinary citizen.

2014Young, 123 Wn.2d at 181 .

2014Young, 123 Wn.2d at 181 .

2009Rather, State v. Bobic, 140 Wn.2d 250 , 996 P.2d 610 (2000) supports the conclusion that commercial storage units do not fall within the constitutional protection of private affairs. ¶15 In Bobic, the manager of a commercial storage facility informed police that one of the units might be connected with stolen vehicles.

2009Rather, State v. Bobic, 140 Wash.2d 250 , 996 P.2d 610 (2000) supports the conclusion that commercial storage units do not fall within the constitutional protection of private affairs. ¶ 15 In Bobic, the manager of a commercial storage facility informed police that one of the units might be connected with stolen vehicles.

2009Next, we determine “whether the expectation of privacy is one that citizens should be entitled to hold.” Andersen v. King County, 158 Wn.2d 1, 44 , 138 P.3d 963 (2006). ¶14 Here, the private affairs inquiry focuses on Lakotiy’s asserted privacy interest in the common area of a gated commercial storage facility, not the storage unit itself. 6 There are no historical protections provided to the common area of commercial storage facilities.

2009Next, we determine "whether the expectation of privacy is one that citizens should be entitled to hold." Andersen v. King County, 158 Wash.2d 1, 44 , 138 P.3d 963 (2006). ¶ 14 Here, the private affairs inquiry focuses on Lakotiy's asserted privacy interest in the common area of a gated commercial storage facility, not the storage unit itself. [6] There are no historical protections provided to the common area of commercial storage facilities.

2009Next, we determine “whether the expectation of privacy is one that citizens should be entitled to hold.” Andersen v. King County, 158 Wn.2d 1, 44 , 138 P.3d 963 (2006). ¶14 Here, the private affairs inquiry focuses on Lakotiy’s asserted privacy interest in the common area of a gated commercial storage facility, not the storage unit itself. 6 There are no historical protections provided to the common area of commercial storage facilities.

2009Next, we determine "whether the expectation of privacy is one that citizens should be entitled to hold." Andersen v. King County, 158 Wash.2d 1, 44 , 138 P.3d 963 (2006). ¶ 14 Here, the private affairs inquiry focuses on Lakotiy's asserted privacy interest in the common area of a gated commercial storage facility, not the storage unit itself. [6] There are no historical protections provided to the common area of commercial storage facilities.

2009Rather, State v. Bobic, 140 Wn.2d 250 , 996 P.2d 610 (2000) supports the conclusion that commercial storage units do not fall within the constitutional protection of private affairs. ¶15 In Bobic, the manager of a commercial storage facility informed police that one of the units might be connected with stolen vehicles.

2009Rather, State v. Bobic, 140 Wash.2d 250 , 996 P.2d 610 (2000) supports the conclusion that commercial storage units do not fall within the constitutional protection of private affairs. ¶ 15 In Bobic, the manager of a commercial storage facility informed police that one of the units might be connected with stolen vehicles.

2014State v. Chacon Arreola, 176 Wn.2d 284, 291-92 , 290 P.3d 983 (2012) (citing State v. Valdez, 167 Wn.2d 761, 772 , 224 P.3d 751 (2009)). ¶9 The private affairs inquiry is broader than the Fourth Amendment’s reasonable expectation of privacy inquiry.

2014State v. Chacon Arreola, 176 Wn.2d 284, 291-92 , 290 P.3d 983 (2012) (citing State v. Valdez, 167 Wn.2d 761, 772 , 224 P.3d 751 (2009)). ¶9 The private affairs inquiry is broader than the Fourth Amendment’s reasonable expectation of privacy inquiry.

2014State v. Chacon Arreola, 176 Wn.2d 284, 291-92 , 290 P.3d 983 (2012) (citing State v. Valdez, 167 Wn.2d 761, 772 , 224 P.3d 751 (2009)). ¶9 The private affairs inquiry is broader than the Fourth Amendment’s reasonable expectation of privacy inquiry.

2014State v. Chacon Arreola, 176 Wn.2d 284, 291-92 , 290 P.3d 983 (2012) (citing State v. Valdez, 167 Wn.2d 761, 772 , 224 P.3d 751 (2009)). ¶9 The private affairs inquiry is broader than the Fourth Amendment’s reasonable expectation of privacy inquiry.