The CI wasn’t supported by past history, but was by controlled buys. United States v. Williams, 2018 U.S. Dist. LEXIS 180895 (W.D. N.Y. Oct. 23, 2018).
“Finally, the affidavit articulated a reasonable nexus between the place to be searched (the phone) and the evidence the police believed they would find, including messages between Derf and Reed.” Pre-Carpenter use of SCA to get CSLI was valid at the time under the good faith exception, and the motion to suppress is denied. United States v. Reed, 2018 U.S. Dist. LEXIS 183967 (D. Minn. Sept. 14, 2018), adopted, 2018 U.S. Dist. LEXIS 181342 (D. Minn. Oct. 22, 2018).*