S.D.N.Y.: No standing to complain of CSLI for somebody else’s phone

Defendants have no standing to challenge the seizure of CSLI on telephone numbers they don’t complain are theirs. United States v. Pizarro, 2018 U.S. Dist. LEXIS 60539 (S.D. N.Y. Apr. 10, 2018).*

Police seizure of an SD card was by consent by somebody with joint authority over it, and the USMJ’s R&R recommending suppression is rejected. A child victim’s statement was an independent source for issuance of the search warrant. United States v. Sukhtipyaroge, 2018 U.S. Dist. LEXIS 60632 (D. Minn. Apr. 10, 2018).*

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