Recent Development: Seal v. State: Pursuant to § 10-402(C)(2)'s Exception to the Wiretap Ban, an Individual is Not Under the Supervision of an Investigative or Law Enforcement Officer When Intercepting an Oral Communication, Absent Restrictions on Equipment Use and Some Subsequent Contact.

Authors

Ashley N. Simmons

Abstract

The Court of Appeals of Maryland held that a detective providing recording equipment to an individual, absent any limitations for use and no interaction thereafter, did not amount to the individual acting under supervision of an investigative or law enforcement officer. Seal v. State, 447 Md. 64, 80, 133 A.3d 1162, 1172 (2016). The court found that guidelines must be given to the person conducting the wiretapping, as well as at least some contact to monitor the progress. Id. at 79-81, 133 A.3d at 1172.

Recommended Citation

Simmons, Ashley N. (2016) "Recent Development: Seal v. State: Pursuant to § 10-402(C)(2)'s Exception to the Wiretap Ban, an Individual is Not Under the Supervision of an Investigative or Law Enforcement Officer When Intercepting an Oral Communication, Absent Restrictions on Equipment Use and Some Subsequent Contact.," University of Baltimore Law Forum: Vol. 47: No. 1, Article 9.
Available at: https://scholarworks.law.ubalt.edu/lf/vol47/iss1/9