In the last quarter the U.S. District Court for the Western District of New York examined a novel question regarding the time within which a pro se plaintiff’s complaint could be served. In another case, the court considered for the first time whether law enforcement violated defendant’s Fourth Amendment privacy interests in information not previously double-clicked and viewed during an initial investigation when officers conducted two warrantless searches of the entire contents of a computer alleged to contain child pornography. A routine substitution of counsel made national headlines in an ongoing dispute over the ownership of Facebook.

Retroactive Extensions

In Bastedo v. N. Rose-Wolcott Cent. Sch. Dist., 10-CV-6162L, 2011 WL 2110812 (W.D.N.Y. May 26, 2011), plaintiff Karen M. Bastedo, proceeding pro se, brought an action against the North Rose-Wolcott Central School District, alleging discrimination and retaliation in violation of the Americans with Disabilities Act, 42 U.S.C. §§12101 et seq.