Defendant is indicted for Hobbs Act robbery, and detectives believed he was in a string of robberies. They obtained ping information on the phone in an attempt to locate him before he committed another robbery. Exigency is shown by the government for the immediate action to get location of the phone to arrest defendant. This was in good faith reliance on the provisions providing for emergency ping orders. United States v. Hammond, 2018 U.S. Dist. LEXIS 182866 (N.D. Ind. Oct. 24, 2018).
CSLI obtained a year before Carpenter with a search warrant was supported by probable cause. United States v. Grim, 2018 U.S. Dist. LEXIS 182860 (D. Del. Oct. 25, 2018).*