Document Type

Note

Category

Community Contributions

Publication Date

2014

Abstract

When the New York State Office of the Inspector General (“NY-OIG”) suspected that a New York State employee named Michael Cunningham was submitting false time reports, its investigators turned to electronic surveillance to assist in their collection of evidence. Without obtaining a judicial warrant, NY-OIG investigators covertly attached a global positioning system (GPS) device to Cunningham’s car and collected data on Cunningham’s vehicular movements twenty-four hours a day for a month, including during his vacation. Ultimately, the GPS data was used in a disciplinary hearing leading to Cunningham’s termination.

Disciplines

Law

Included in

Law Commons

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