WaPo: Applying the Fourth Amendment to cell-site simulators

WaPo: Applying the Fourth Amendment to cell-site simulators by Orin Kerr:

The widespread use of cellphones gives the government a way to locate criminal suspects using a device known as a cell-site simulator. The Maryland Court of Special Appeals recently handed down the first appellate decision on whether and when use of a cell-site simulator to identify the location of a target’s phone is a Fourth Amendment “search.” The opinion, in State v. Andrews, rules that government use of a cell-site simulator is always a Fourth Amendment search and that it ordinarily requires a warrant.

I think that result is plausible, but I found the court’s path to that result rather frustrating. This post explains why.