TX: No SW needed for historical SCLI

“Did the State’s warrantless acquisition of four days worth of historical cell-site-location information—recorded by Jon Thomas Ford’s cell-phone service provider—violate the Fourth Amendment? No. We agree with the San Antonio Court of Appeals that, because a third-party, AT&T, gathered and maintained the information as business records of the service provided to Ford’s phone, Ford did not have a reasonable expectation of privacy in the data. The State did not violate Ford’s Fourth Amendment rights when it obtained that information by way of a court order under Article 18.21 § 5(a) of the Texas Code of Criminal Procedure—an order available on a showing short of probable cause. We will affirm.” Ford v. State, 2015 Tex. Crim. App. LEXIS 1412 (Dec. 16, 2015).