“The U.S. Department of Justice and the FBI believe they don’t need a search warrant to review Americans’ e-mails, Facebook chats, Twitter direct messages, and other private files, internal documents reveal.”
This article discusses the use of administrative subpoenas (which may or may not have probable cause) to demand access to emails, based on the Electronic Communications Privacy Act. The act allows emails older than six months to be administratively subpoenaed without a search warrant. This was modified by a Sixth Circuit opinion in 2010.
From C-net, read the entire article here:
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