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icion is not needed for customs officials to search a laptop or other personal electronic storage devices at the border," Arnold, 533 F.3d at 1008, the Ninth Circuit stands alone, as it so often does. The majority likens the search of Cotterman's laptop to a "computer strip search," Majority at 966, and proceed
thority expansively. See 473 U.S. at 539-40. 542-44, 105 S.Ct. 3304. 3 See, e.g.. Flores-Montano. 541 U.S. at 152-55. 124 S.Ct. 1582 (overturning the Ninth Circuit's conclusion that the border search of a gas tank required reasonable suspicion): Ramsey, 431 U.S. at 616-22.97 S.Ct. 1972 (overturning the ■. Circu
, the Fourth Circuit found jurisdiction based on Perlman in a civil case, Mezu v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising under 28 U.S.C. §2255, United States v. Gonzalez, 669 F.3d 974, 977 n.2 (9th Cir. 2012), and in a civil case,
from an order compelling the testimony of their former attorney over a claim of attorney-client privilege. The 10 EFTA00583769 Court agreed with the Ninth Circuit's decision in Krane, concluding that the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise th
, the Fourth Circuit found jurisdiction based on Perlman in a civil case, Mezu v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising under 28 U.S.C. §2255, United States v. Gonzalez, 669 F.3d 974, 977 n.2 (9th Cir. 2012), and in a civil case,
terlocutory appeal from an order compelling the testimony of their former attorney over a claim of attorney-client privilege. The Court agreed with the Ninth Circuit's decision in Krane, concluding that the circumstances in Krane "support application of the Perlman doctrine because, without the ability to raise th
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