Devenpeck v. Alford

Officer Devenpeck (defendant) arrested Alford (defendant in the caption, functionally the plaintiff) for violating the state Privacy Act after noticing Alford recording their roadside conversation, even though Alford's earlier suspicious conduct (giving stranded motorists the impression he was a police officer, carrying handcuffs and a police scanner) could have separately supported probable cause for impersonating or obstructing an officer; the Ninth Circuit held no probable cause existed because those alternative offenses weren't "closely related" to the recording-based offense Devenpeck actually invoked at the time.