Carpenter’s search warrant requirement does not apply to cell phone records merely used to show that co-conspirators communicated with each other. In light of the whole trial, it wasn’t all that important. People v. Anderson, 2018 Cal. LEXIS 4698 (June 28, 2018).
Blocking defendant’s vehicle to keep it from leaving is a seizure, and it had to be based on reasonable suspicion. “In this case, when the officers seized Harger’s vehicle, the only information known to them consisted of (1) the two anonymous tips; (2) Harger’s location, across the street from a youth center; and (3) Griffin’s professed knowledge that the Bayview neighborhood of San Francisco is a ‘narcotics-prone and violent crime-prone area.’ See Griffin Decl. ¶¶ 2-6. This information did not provide reasonable suspicion to justify seizure of Harger’s vehicle under the Fourth Amendment.” United States v. Harger, 2018 U.S. Dist. LEXIS 107698 (N.D. Cal. June 28, 2018).*