Noting pendency of Carpenter, the Tenth Circuit finds CSLI third-party records and they are bound to apply the third-party doctrine. United States v. Thompson, 2017 U.S. App. LEXIS 14551 (10th Cir. Aug. 8, 2017).
Defendant had a warrantless search condition on his release from confinement as a part of his sentence, and reasonable suspicion wasn’t required, although they did have it. State v. Summers, 2017 Tenn. Crim. App. LEXIS 698 (Aug. 8, 2017).*
The officers had knowledge of defendant’s probation search condition before the search, and the “probation compliance search” was reasonable. United States v. King, 2017 U.S. Dist. LEXIS 124383 (S.D. Cal. Aug. 7, 2017).*