First Circuit: Boudreau v. Lussier

Expert testimony is required to establish that time-stamped screenshots taken of employees computer are, for purposes of the statute, contemporaneous intercepts of electronic communications.

Impoundment and subsequent inventory search of arrestee's vehicle from employer's private lot were justified under the community caretaker exception; even if the motive was investigatory, subjective intent is irrelevant, and the towing was objectively justified.

Employer defts would be protected by qualified immunity for consenting to search of employees computer where their authority to do so was not plain.

http://media.ca1.uscourts.gov/pdf.opinions/16-1049P-01A.pdf