Conviction for child rape vacated on two grounds: erroneous jury instruction on statute of limitations tolling and insufficient corroborating evidence. Corroboration must relate to specific charged acts, not uncharged misconduct.
Warrantless seizure of cellular telephone improper where police lack particularized information that device contains evidence of crime, even with probable cause to suspect defendant. Unreasonable delay in obtaining warrant also requires suppression.
Search incident to arrest for prior drug offense unlawful; inventory search cannot transform into investigative examination without warrant; plain view seizure requires immediately apparent incriminating character.
Courtroom closure during general jury questioning violated defendant's Sixth Amendment right to public trial despite brief duration; not de minimis.
Affirmed on title claim; vacated and remanded on prescriptive easement claim. Eroded beach parcel held subject to fixed landward boundary despite seaward migration.
