reasonable expectation of privacy analysis (New Hampshire) · Go Syfert
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reasonable expectation of privacy analysis in New Hampshire

12 New Hampshire opinions name it 1 courts 1987–2017 0 in the last five years

The cases below were cited by New Hampshire courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
State v. Gossgreen
nh · 2003 · cited in 5 New Hampshire opinions naming this issue, 2004–2017
2 sentences

2017In Goss , we determined that the "time [had] come to adopt explicitly a reasonable expectation of privacy analysis under Part I, Article 19." Id.

2005In State v. Goss, 150 N.H. 46 (2003), for the first time, we adopted a reasonable expectation of privacy analysis under Part I, Article 19 of the New Hampshire Constitution.

25
State v. Pinkhamgreen
nh · 1996 · cited in 3 New Hampshire opinions naming this issue, 1997–2004
2 sentences

2004Although we did not analyze the facts in Pinkham under the reasonable expectation of privacy framework, we held that the defendant’s driveway was not constitutionally protected because it was visible from the road, not blocked by fences or shrubbery, and not “posted with ‘No Trespassing’ signs.” Id. at 191 .

1999Accordingly, we postpone consideration of the reasonable expectation of privacy test until another day.” State v. Pinkham, 141 N.H. 188, 189-90 , 679 A.2d 589, 590 (1996) (citation omitted); see State v. Valenzuela, 130 N.H. 175, 181 , 536 A.2d 1252, 1256-57 (1987), cert. denied, 485 U.S. 1008 (1988).

23
State v. Valenzuelagreen
nh · 1987 · cited in 2 New Hampshire opinions naming this issue, 1990–1999
2 sentences

1999Accordingly, we postpone consideration of the reasonable expectation of privacy test until another day.” State v. Pinkham, 141 N.H. 188, 189-90 , 679 A.2d 589, 590 (1996) (citation omitted); see State v. Valenzuela, 130 N.H. 175, 181 , 536 A.2d 1252, 1256-57 (1987), cert. denied, 485 U.S. 1008 (1988).

1999Accordingly, we postpone consideration of the reasonable expectation of privacy test until another day.” State v. Pinkham, 141 N.H. 188, 189-90 , 679 A.2d 589, 590 (1996) (citation omitted); see State v. Valenzuela, 130 N.H. 175, 181 , 536 A.2d 1252, 1256-57 (1987), cert. denied, 485 U.S. 1008 (1988).

22
Schroeder v. United Statesgreen
scotus · 1988 · cited in 2 New Hampshire opinions naming this issue, 1990–1999
2 sentences

1999Accordingly, we postpone consideration of the reasonable expectation of privacy test until another day.” State v. Pinkham, 141 N.H. 188, 189-90 , 679 A.2d 589, 590 (1996) (citation omitted); see State v. Valenzuela, 130 N.H. 175, 181 , 536 A.2d 1252, 1256-57 (1987), cert. denied, 485 U.S. 1008 (1988).

1990See State v. Valenzuela, 130 N.H. 175, 180-81 , 536 A.2d 1252, 1256-57 (1987), cert. denied, 485 U.S. 1008 (1988).

22
State v. Smithgreen
nh · 2012 · cited in 2 New Hampshire opinions naming this issue, 2015–2017
2 sentences

2017Under our test, a constitutional violation occurs when a warrantless search takes place in an area in which (1) the person has "exhibited a subjective expectation of privacy in the area" and (2) "that expectation [is] one that society is prepared to recognize as reasonable," State v. Smith , 163 N.H. 169 , 172, 37 A.3d 409 (2012), and the search does not fit within one of the exceptions to the warrant requirement, see State v. Smith , 169 N.H. 602 , 607, 154 A.3d 660 , 664 (2017) (explaining that *641 Part I, Article 19 of the State Constitution is violated when "government agents invade a per

2017Under our test, a constitutional violation occurs when a warrantless search takes place in an area in which (1) the person has "exhibited a subjective expectation of privacy in the area" and (2) "that expectation [is] one that society is prepared to recognize as reasonable," State v. Smith , 163 N.H. 169 , 172, 37 A.3d 409 (2012), and the search does not fit within one of the exceptions to the warrant requirement, see State v. Smith , 169 N.H. 602 , 607, 154 A.3d 660 , 664 (2017) (explaining that *641 Part I, Article 19 of the State Constitution is violated when "government agents invade a per

12
United States v. Jonesgreen
scotus · 2012 · cited in 1 New Hampshire opinions naming this issue, 2015–2015
1 sentence

2015See Jardines, 133 S. Ct. at 1417 ; see also Jones, 132 S. Ct. at 952 (stating that the “reasonable-expectation-of-privacy test has been added to, not substituted for, the common-law trespassory test”); United States v. Duenas, 691 F.3d 1070, 1080-81 (9th Cir.2012) (explaining that in Jones , “the Court reaffirmed that the home and its curtilage are sacrosanct” and that courts are not required “to apply the reasonable expectation of privacy standard in addition to finding that the subject of the search was ‘persons, houses, papers, or effects’ ” (brackets omitted)).

11
United States v. Raymond Duenas, Jr.green
ca9 · 2012 · cited in 1 New Hampshire opinions naming this issue, 2015–2015
1 sentence

2015See Jardines, 133 S. Ct. at 1417 ; see also Jones, 132 S. Ct. at 952 (stating that the “reasonable-expectation-of-privacy test has been added to, not substituted for, the common-law trespassory test”); United States v. Duenas, 691 F.3d 1070, 1080-81 (9th Cir.2012) (explaining that in Jones , “the Court reaffirmed that the home and its curtilage are sacrosanct” and that courts are not required “to apply the reasonable expectation of privacy standard in addition to finding that the subject of the search was ‘persons, houses, papers, or effects’ ” (brackets omitted)).

11
Florida v. Jardinesgreen
scotus · 2013 · cited in 1 New Hampshire opinions naming this issue, 2015–2015
1 sentence

2015See Jardines, 133 S. Ct. at 1417 ; see also Jones, 132 S. Ct. at 952 (stating that the “reasonable-expectation-of-privacy test has been added to, not substituted for, the common-law trespassory test”); United States v. Duenas, 691 F.3d 1070, 1080-81 (9th Cir.2012) (explaining that in Jones , “the Court reaffirmed that the home and its curtilage are sacrosanct” and that courts are not required “to apply the reasonable expectation of privacy standard in addition to finding that the subject of the search was ‘persons, houses, papers, or effects’ ” (brackets omitted)).

11
State v. Alosagreen
nh · 1993 · cited in 1 New Hampshire opinions naming this issue, 1996–1996
2 sentences

1996See, e.g., State v. Sterndale, 139 N.H. 445, 449 , 656 A.2d 409, 411 (1995); State v. Alosa, 137 N.H. 33, 37 , 623 A.2d 218, 221 (1993).

1996See, e.g., State v. Sterndale, 139 N.H. 445, 449 , 656 A.2d 409, 411 (1995); State v. Alosa, 137 N.H. 33, 37 , 623 A.2d 218, 221 (1993).

11
State v. Westovergreen
nh · 1995 · cited in 1 New Hampshire opinions naming this issue, 1996–1996
2 sentences

1996State v. Westover, 140 N.H. 375, 379 , 666 A.2d 1344, 1348 (1995).

1996State v. Westover, 140 N.H. 375, 379 , 666 A.2d 1344, 1348 (1995).

11
State v. Sterndalegreen
nh · 1995 · cited in 1 New Hampshire opinions naming this issue, 1996–1996
2 sentences

1996See, e.g., State v. Sterndale, 139 N.H. 445, 449 , 656 A.2d 409, 411 (1995); State v. Alosa, 137 N.H. 33, 37 , 623 A.2d 218, 221 (1993).

1996See, e.g., State v. Sterndale, 139 N.H. 445, 449 , 656 A.2d 409, 411 (1995); State v. Alosa, 137 N.H. 33, 37 , 623 A.2d 218, 221 (1993).

11
United States v. Victor F. Maganagreen
ca9 · 1975 · cited in 1 New Hampshire opinions naming this issue, 1996–1996
1 sentence

1996See Magana, 512 F.2d at 1170-71 ; State v. Cloutier, 544 A.2d 1277, 1279-80 (Me. 1988), abrogated on other grounds by Horton v. California, 496 U.S. 128 (1990).

11
State v. Cloutiergreen
me · 1988 · cited in 1 New Hampshire opinions naming this issue, 1996–1996
1 sentence

1996See Magana, 512 F.2d at 1170-71 ; State v. Cloutier, 544 A.2d 1277, 1279-80 (Me. 1988), abrogated on other grounds by Horton v. California, 496 U.S. 128 (1990).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Hampshire. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Katz v. United States green
scotus · 1967
2 sentences

1997The defendant first asserts that part I, article 19 protects not only her person and property, but also her “reasonable expectation of privacy in her medical records.” Cf. Katz v. United States, 389 U.S. 347 (1967) (adopting the reasonable expectation of privacy analysis for purposes of determining whether an invaded interest is one that is protected under the fourth amendment of the Federal Constitution).

1987Batchelder, J., dissenting: I agree with the majority that the defendant has asked us to determine the scope of the protections under part I, article 19 of the New Hampshire Constitution by employing the reasonable expectation of privacy analysis in Katz v. United States, 389 U.S. 347 (1967).

31987–2003
State v. Robert Grimpson Smith green
nh · 2017
2 sentences

2017Under our test, a constitutional violation occurs when a warrantless search takes place in an area in which (1) the person has "exhibited a subjective expectation of privacy in the area" and (2) "that expectation [is] one that society is prepared to recognize as reasonable," State v. Smith , 163 N.H. 169 , 172, 37 A.3d 409 (2012), and the search does not fit within one of the exceptions to the warrant requirement, see State v. Smith , 169 N.H. 602 , 607, 154 A.3d 660 , 664 (2017) (explaining that *641 Part I, Article 19 of the State Constitution is violated when "government agents invade a per

2017Under our test, a constitutional violation occurs when a warrantless search takes place in an area in which (1) the person has "exhibited a subjective expectation of privacy in the area" and (2) "that expectation [is] one that society is prepared to recognize as reasonable," State v. Smith , 163 N.H. 169 , 172, 37 A.3d 409 (2012), and the search does not fit within one of the exceptions to the warrant requirement, see State v. Smith , 169 N.H. 602 , 607, 154 A.3d 660 , 664 (2017) (explaining that *641 Part I, Article 19 of the State Constitution is violated when "government agents invade a per

12017–2017
Delaware v. Prouse green
scotus · 1979
1 sentence

2004Id. at 654-55 ; see State v. Goss, 150 N.H. 46, 48-49 (2003) (adopting the reasonable expectation of privacy analysis under Part I, Article 19).

12004–2004
Horton v. California green
scotus · 1990
1 sentence

1996See Magana, 512 F.2d at 1170-71 ; State v. Cloutier, 544 A.2d 1277, 1279-80 (Me. 1988), abrogated on other grounds by Horton v. California, 496 U.S. 128 (1990).

11996–1996
AMP Inc. v. General Motors, Inc. green
scotus · 1967
1 sentence

1996We have not yet adopted the reasonable expectation of privacy test, see Katz v. United States, 389 U.S. 847 , 361 (1967) (Harlan, J., concurring), to interpret part I, article 19.

11996–1996

Statutes the citing opinions construe

NH § N.H. Rev. Stat. Ann. § 318-B:2 (7)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NH 12 (1987–2017) NJ 11 (2008–2025) ID 11 (2019–2025) WI 10 (2000–2026) CT 10 (1993–2025) IA 8 (2015–2025) TX 8 (1984–2025) OR 7 (1987–2019) AZ 6 (1982–2021) VT 5 (1987–2019) MD 4 (2001–2013) OH 4 (2000–2025) CA 4 (1971–2014) IL 3 (2015–2016) PA 3 (1989–2025) IN 3 (1980–2017) MI 3 (1986–2003) NY 3 (1987–2009) FL 3 (1981–2020) HI 3 (2002–2017) MN 2 (2016–2018) KS 2 (2007–2015) NC 2 (2014–2016) MA 2 (2013–2013) NE 2 (2013–2014) SD 2 (2012–2017) CO 2 (1985–2019) WV 2 (1985–1989) MT 2 (2008–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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