Fifth Circuit -- Fannie Garcia v. City of Laredo (12/12)

Stored Communications Act does not apply to information stored in a directly accessed cell phone, as it is not a 'facility' as contemplated by the statute and the information is not in 'electronic storage.'

Where counsel makes ex parte contact with judge and is admonished and judge later criticizes the quality of the lawyer's work, the judge is not required to recuse him or herself.

Fannie Garcia v. City of Laredo