Which of the Following Is NOT an Instance Wherein a Police

Which of the following is NOT an instance wherein a police officer can record a conversation without a warrant?

A) Surreptitiously recorded conversations during a routine traffic stop
B) When law enforcement officials have a victim contact an offender via telephone and have the victim attempt to illicit incriminating statements
C) While offenders are handcuffed in the back seat of a police vehicle
D) none of the above