DE applies Carpenter to January CSLI search; no action yet on state’s effort to get it again after motion to suppress

Defendant was the subject of a CSLI warrant in January 2018. After he filed a motion to suppress under Carpenter decided in June, the state sought the same information by a search warrant in August 2018. Carpenter applies here. The state pleads the independent source doctrine, but the court can’t decide that now. State v. Rone, 2018 Del. Super. LEXIS 396 (Sep. 20, 2018).

Defendant’s stop for trespassing again on the victim’s property was with reasonable suspicion, and the reasonable suspicion escalated the longer the stop went on. United States v. Marin, 2018 U.S. Dist. LEXIS 161080 (N.D. Iowa July 26, 2018).*

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