State v. Armstrong

Police seized incriminating text messages that the defendant sent to his ex-girlfriend. Defendant moved to suppress the messages, as they were recovered from the ex-girlfriend’s phone without a warrant. The Appellate Division held that the defendant had neither a reasonable expectation of privacy in the text message recovered from his girlfriend’s cellphone, nor did he have standing to challenge the search of the phone and seizure of the messages. 

State-v.-Armstrong