United States v. Zhu
United States District Court for the Southern District of New York
41 F. Supp. 3d 341 (2014)

- Written by Miller Jozwiak, JD
Facts
Yudong Zhu (defendant) was a medical professor at a university, where he specialized in magnetic resonance imaging (MRI). Zhu received a grant from the National Institutes of Health to conduct MRI research. The university was the property owner of the grant funds and the equipment purchased with those funds. Zhu later used the funds to purchase a laptop, which he used for personal and professional matters. The university later investigated Zhu for misusing the grant funds. Zhu gave the university officials the laptop but refused to disclose the laptop’s passwords. The university officials then gave the laptop to the Federal Bureau of Investigation (FBI), and the university’s counsel authorized the FBI to search the laptop. The FBI conducted the search without obtaining a warrant. Criminal charges were later brought against Zhu. Zhu moved to suppress the information on the laptop as an unlawful warrantless search. The district court denied the motion on the grounds that the search was subject to valid third-party consent. After the United States Supreme Court decided Riley v. California, Zhu moved for reconsideration of his motion to suppress.
Rule of Law
Issue
Holding and Reasoning (Marrero, J.)
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