E.D.Pa.: Pre-Carpenter CSLI survives with GFE; Riley didn’t foretell Carpenter

Defendant was a suspect in a series of bank robberies, and a court order was obtained for his CSLI in 2016. Defendant’s argument that Riley foretold Carpenter is rejected. It wasn’t enough to forecast a clear outcome. The good faith exception applies. United States v. Boyle, 2018 U.S. Dist. LEXIS 166096 (E.D. Pa. Sep. 17, 2018).

The government’s 11 month delay in extracting information from a cell phone doesn’t warrant dismissal, but it does warrant a continuance. United States v. Crable, 2018 U.S. Dist. LEXIS 166454 (D. Kan. Sep. 27, 2018).

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