D.Md.: Obtaining defendant’s CSLI six years before Carpenter was lawful; no 2255 relief

Obtaining defendant’s CSLI six years before Carpenter was lawful, and it doesn’t form a basis for relief now. Osiomwan v. United States, 2018 U.S. Dist. LEXIS 200033 (D. Md. Nov. 27, 2018).*

Defendant’s statements to the police were voluntary despite not being told that a search warrant had been executed. After defendant learned about that he kept talking. United States v. Tangtong, 2018 U.S. Dist. LEXIS 200000 (W.D. Va. Nov. 27, 2018).*

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