D.Neb.: Cell phone GPS location was obtained by court order under § 2703 so GFE applies

Cell phone GPS location data was obtained by HSI with a court order on probable cause. While it wasn’t under Rule 41, it was clearly covered by good faith under § 2703. United States v. Garcia, 2014 U.S. Dist. LEXIS 106394 (D. Neb. August 4, 2014).

Defendant was walking with “B” whom the officers knew there was an arrest warrant out for. The officers told both to stop and they didn’t. There was no reasonable suspicion as to defendant at all until he fled with B and dropped a bag of drugs. The seizure was thus lawful. State v. Kelly, 2014 Conn. LEXIS 263 (August 12, 2014).*

Officers received information that defendant was a felon in possession of a shotgun and that he’d threatened somebody with it. Another officer saw his vehicle while running radar and noted traffic violations and stopped him. The stop was lawful for that alone, but there was also reasonable suspicion he was armed in violation of the law. The gun was lawfully seized. United States v. Harken, 2014 U.S. Dist. LEXIS 105984 (N.D. Iowa August 1, 2014).*