Oregon District Court holds eBay records fall within the third-party doctrine.

In this case, the defendant is charged with assault on a federal officer, one count of carrying and using a destructive device during and in relation to a crime of violence, using an explosive to commit a federal felony, and carrying an explosive during the commission of a federal felony.

The relevant part of the discussion for our purposes is that the defendant made a series of online purchases from eBay where FBI agents learned about the purchases. A number of chemicals were purchased that could be used to make explosives.

Agents obtained a search warrant for the defendant’s apartment based in part on information provided by eBay. Ebay gave up this information voluntarily. and later in response to a grand jury subpoena. The Defendant argued using Carpenter, that the Ebay records transactions were his personal property and effects in a virtual desk.

The Court, after giving a brief legal history of the third-party doctrine, held that these records fell squarely within the third-party doctrine. since location records are not at issue here.

The case is United States v. Schaefer, 2019 U.S. Dist. LEXIS 8505, 2019 WL 267711 (D. Oregon) January 17, 2019.

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