State v. Hubka
In State v. Hubka, 10 Ariz. App. 595, 461 P.2d 103 (1969), the defendant sent a letter to an addressee at a fire station, offering to pay him to kill her husband, but the addressee was not there when the letter arrived. Id. at 596, 461 P.2d at 104.
Before the addressee picked up the letter, a member of the fire department held it up to the light, saw part of its contents, and called police. Id.
Without a warrant, a police officer opened and read the letter. Id.
In finding that Hubka had standing to challenge the seizure, the court discussed 18 U.S.C. 1702 and Maxwell, concluding that a letter sent through the mail should be protected from unreasonable searches and seizures "until actual receipt by the addressee." Id. at 597, 461 P.2d at 105.