The Sixth Circuit has held, in Huff v. Spaw, that a person has no reasonable expectation of privacy in the content of a face-to-face conversation if he accidentally places a “pocket-dial” call on his cell phone during the conversation and the recipient of the call listens in on that conversation.  Accordingly, the court ruled that the person who unwittingly placed the call could not state a claim under the Wiretap Act against the person who listened to the conversation and later disclosed her notes and a recording of parts of it.  However, his wife ‒ whose statements were also heard during the call ‒ did have a claim under the Act, since she was not responsible for placing the call.