Defendant was on probation and had GPS monitoring as a condition. It was reasonable for the state to access the historical GPS data later when defendant was suspected of a crime. Commonwealth v. Johnson, 481 Mass. 710 (Mar. 26, 2019).
The time for bringing a Rule 41(g) claim runs from the expiration of the statute of limitations for filing the criminal or civil forfeiture case. If criminal proceedings were filed, the time runs from the end of the criminal proceedings. United States v. Ioane, 2019 U.S. Dist. LEXIS 49619 (E.D. Cal. Mar. 26, 2019).*