Pride

INTRODUCTION

*135 A jury convicted Chaz Nasjhee Pride of robbery ( Pen. Code, § 211 ; count 1) 1 and found true allegations he committed the robbery for the benefit of, or at the direction of, and in association with a criminal street gang (§ 186.22, subd. (b)(1) ). 2 In a bifurcated proceeding, Pride admitted two prior prison offenses (§§ 667.5, subd. (b), 668) and the court found true allegations Pride previously committed a strike offense (§§ 667, subds. (b)-(i), 668, *299 1170.12) and a serious felony prior (§§ 667.5, subd. (a), 668, 1192). The court sentenced Pride to 21 years in prison based upon six years for the robbery (double the midterm of three years) plus 10 years for the gang enhancement and five years for the serious felony prior. The court struck one of the prison prior allegations and stayed punishment on the second prison prior because it arose from the same conduct that resulted in the serious felony prior.

Pride contends his rights under the Fourth Amendment to the United States Constitution and the Electronic Communications Privacy Act (ECPA) (§ 1546, *136 et seq.) were violated when a police detective viewed and saved a copy of a video Pride posted on a…