Carpenter doesn’t change the third-party doctrine as to IP information. United States v. McCutchin, 2019 U.S. Dist. LEXIS 36811 (D. Ariz. Mar. 7, 2019).
The affidavits “are somewhat thin,” but this is deferential, not de novo, review, and, while this court might have required more, the court cannot say that there was no substantial basis for issuance of the warrant. Also, referring to the information in the affidavit as coming from a concerned citizen and not as a confidential informant was misleading, but the information was still substantial enough for probable cause. United States v. Thompson, 2019 U.S. Dist. LEXIS 36951 (D. Minn. Jan. 7, 2019).*