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Name: People v. Reyes
Case #: G038778
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 10/30/2009

For Fourth Amendment purposes, a person has no reasonable expectation of privacy as to the exterior of an item received by a private mail receiving business. During the investigation of the kidnapping of the victim, police officers went to the postal box appellant had rented from a private mail receiving company and asked if defendant had received mail. The clerk responded by reaching into defendant’s postal box, retrieving three letters, and, without opening them, displayed them to the officers. The outside of one of the letters indicated that it was a bill from AT&T wireless. With this information, police obtained a warrant for defendant’s AT&T cell phone records which then linked appellant to the crime. The court upheld the denial of appellant’s suppression motion, noting that a party has no reasonable expectation of privacy as to the outside of an item stored in a common area. Mail facility operations are such that employees have ready access to the mailbox, during which time the exterior of contents stored therein are readily available to the view of many; thus, the renter of the box can have no reasonable expectation of privacy in the exterior of such contents.