Pre-trial detainees do not have a reasonable expectation of privacy in their holding cell. A Florida appellate court reached this basic conclusion following a saga involving murder, a tell-tale spouse, an attempted suicide, and a suicide note.

Oscar Bolin was accused of murdering two women. In jail awaiting trial, Mr. Bolin was quite busy. He attempted to escape, smashing a piece of metal in the face of a prison guard. He tried plotting with his girlfriend to kidnap members of the sheriff's and judge's family. All of his plans, including an effort commit suicide, were unsuccessful. Perhaps his most damaging act was the suicide note he wrote and left in plain view next to the toilet in his cell. It was addressed to and discovered by the homicide investigator of his case. The note contained information about the alleged murders.

At Mr. Bolin's murder trial, his former wife provided key testimony about conversations she had with him. He was convicted of both counts of murder. The Supreme Court reversed the convictions because Mr. Bolin had not waived his spousal privilege, thereby rendering his former wife's testimony inadmissible. However, the court left open the possibility that Mr. Bolin waived the spousal privilege of confidentiality by writing the suicide note addressed to the homicide investigator. Unfortunately for the state, the trial court ruled the letter inadmissible because it was obtained in violation of Mr. Bolin's right to privacy.

On appeal, the court held that a reasonable person in custody would not have an expectation of privacy in a prison cell. The state's search and seizure of the suicide note met constitutional standards and the letter would be introduced as evidence.