State v. Brooks
In State v. Brooks, 157 Vt. 490, 493, 601 A.2d 963, 964 (1991), the Court considered a challenge to participant electronic monitoring where the wired informant and the defendant were in two adjacent vehicles in a parking lot.
Applying the same "reasonable expectation of privacy analysis," the Court held that such monitoring was not regulated by Article 11:
"We find that defendant, regardless of what he actually expected, did not enjoy a reasonable expectation of privacy in a public parking lot." Id. at 493, 601 A.2d at 964.