Does the "incidental overhear" doctrine apply to a motion to suppress evidence?

^16. When reviewing a district court's denial of a motion to suppress evidence, we review the court's legal determinations de novo and its factual findings for clear error. United States v. Boles, 914 F.3d 95, 102 (2d Cir. 2019). The issues on appeal are legal, and therefore our review here is de novo.

^17. The "incidental overhear" doctrine is closely related to the "plain view" doctrine applied in connection with physical searches. See, e.g., Coolidge v. New Hampshire, 403 U.S. 443, 465-67 (1971) (describing plain view doctrine and noting that "[t]he doctrine serves to supplement the prior justification whether it be a warrant . . . , hot pursuit, search incident to lawful arrest, or some other legitimate reason for being present unconnected with a search directed against the accused and permits the warrantless seizure.").