Defendants were charged with a series of ATM robberies, and the government sought historical CSLI to link the defendants together. This is third party information. The fact that information was sought for over a year in some of the defendants’ cases isn’t determinative of unreasonableness because the period of the crimes covers over two years. Plus, CSLI isn’t as intrusive as GPS because it’s approximate. United States v. Brown, 2017 U.S. Dist. LEXIS 154374 (D. Neb. Aug. 23, 2017), adopted, 2017 U.S. Dist. LEXIS 152864 (D. Neb. Sept. 20, 2017).
Another Playpen warrant sustained. United States v. Scanlon, 2017 U.S. Dist. LEXIS 151471 (D. Vt. April 26, 2017).*