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Travis Stearns, Washington Defender Association, Seattle, WA, Amicus Curiae on behalf of Washington Defender Association. The sender addresses mail to a particular individual and reasonably expects the communication to be routed to and received by the addressee. We decline to find there was no interception here based on the fact that the messages were in electronic storage when they reached the phone—a technicality that has no relevance under our state statute. Likewise, there is no indication that the legislature intended to protect an intended recipient's ability to access a communication. Lila Jane Silverstein, Washington Appellate Project, Seattle, WA, Amicus Curiae on behalf of Washington Association of Criminal Defense Lawyers. Fakhoury, Electronic Frontier Foundation, San Francisco, CA, Venkat Balasubramani, Focal PLLC, Seattle, WA, Amicus Curiae on behalf of Electronic Frontier Foundation. Reading a letter addressed to another individual certainly does not render that person the intended recipient, and the ordinary meaning of “intercept” would encompass opening and reading a letter in someone else's mailbox before they receive it. WAPA calls to our attention to federal cases that exclude stored electronic and wire communications from the protection of the federal wiretap statute. Steiger, 318 F.3d 1039, 1048 (11th Cir.2003); Fraser v. Conclusion¶ 26 When the detective intercepted Roden's text messages to Lee, officers had already booked Lee into jail, and the State does not argue that exigent circumstances required a warrantless search of the phone. Ed.2d 374 (1966) (defendant who allows confidential government informant into hotel suite cannot claim Fourth Amendment protection); Osborn v. To reiterate, the statute was intended to prohibit electronic eavesdropping, where the eavesdropper overhears an ongoing communication, regardless of whether the intended recipient receives the communication.

• She was in Boise at some point in 1988 • She had a PO box in Boulder City, Nevada in the late 1980s • She had very long hands, and said she had been a hand model • She may have had a nose job at some point • She had breast implants • She was very religious • She was a vegetarian • She may have had ADHD, OCD, or Tourette's Syndrome • She said she loved Cuban food • Claimed to have suffered from bulimia • Was a dancer at a Dallas-area nightclub when she was attending college (Fox News) • Had a miscarriage when trying to conceive a baby with husband • Had student loans, filed for bankruptcy (1990’s) • Investigators believe she came from the Pacific Northwest or West Coast.

They've got a huge grocery section, lawn & garden, a huge hardware store built in, electronics, music, software, videos, a deli, sometimes a big built-in eating area and a lot of other things that I'm probably leaving out.

All in all it's not a bad store but that didn't stop what I did to them.

¶ 1 We are asked to decide whether Washington's privacy act protects text messages intercepted by a detective who possessed the intended recipient's cell phone after a warrantless seizure. See Webster's, supra, at 1176.¶ 23 WAPA also suggests that there was no interception because once the text messages reached the phone, they were in electronic storage and fell outside the scope of the act. There is simply no evidence that there was insufficient time for law enforcement officials to seek a court order. Accordingly, “intercept” most likely refers to acquisition of a communication during transmission. A strict interpretation comports with the plain meaning of “intercept” and makes clear what conduct is criminal¶ 42 The majority adopts a liberal interpretation of “intercept.” It apparently reads “before arrival” broadly as meaning “before the intended recipient accesses the communication.” Because this is a criminal statute, I would adopt a strict construction.

A police detective spent 5 to 10 minutes browsing through a cell phone officers took from Daniel Lee incident to his arrest for possession of heroin. App.2012) (noting that “society's continued expectation of privacy in communications made by letter or phone call demonstrates its willingness to recognize a legitimate expectation of privacy in the contents of text messages”). We have found information willingly imparted to an unidentified stranger falls outside the protection of the act, as do some conversations that take place in “the presence of one or more third parties” in a “marketplace atmosphere.” Clark, 129 Wn.2d at 228. We find that the privacy act was violated because the detective intercepted Roden's private communications without Lee's or Roden's consent and without a court order. That is, I would read “before arrival” as meaning simply “before a message reaches its intended destination,” thereby providing clarity as to what actions constitute an unlawful intercept. Bell, 83 Wn.2d 383, 388, 518 P.2d 696 (1974) (in criminal cases, fairness dictates that statutes should be literally and strictly construed; courts should refrain from using possible but strained interpretations).¶ 43 The statute does not define “intercept.” A nontechnical term left undefined in a statute is given its plain and ordinary meaning, as defined in a standard dictionary. Sullivan, 143 Wn.2d 162, 174–75, 19 P.3d 1012 (2001); State v.. Thus, as the majority notes, “intercept” means to “stop ․ before arrival ․ or interrupt the progress or course.” Majority at 11 (alterations in original) (citing Webster's Third New International Dictionary 1176 (2002)).¶ 44 In other words, an interception must occur “before arrival” or before a message has reached the end of its journey.