In United States v. Amanuel,1 the U.S. Court of Appeals for the Second Circuit gave its most recent pronouncement and clarification of federal electronic surveillance law concerning the recording and sealing of lawfully intercepted electronic communications.

In reversing and remanding the case, the circuit reversed the district court’s suppression of all the electronic and derivative evidence against defendants, and held that the failure by police to record electronically and to seal the recordings of electronic pager communications as required by 18 U.S.C. §2518(8)(a) did not amount to a constitutional violation requiring suppression of derivative evidence.

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