The search warrant was challenged as a general warrant, but the court finds that it specified the crime under investigation, and that limited it. “Although the specific electronics recovered were not part of [one] burglary, those devices were nevertheless well within the scope of the search warrant.” United States v. Thomas, 2019 U.S. Dist. LEXIS 72340 (E.D. Va. Apr. 24, 2019).
Pre-Carpenter warrantless obtaining of CSLI is admissible, but the court doesn’t like it: “Though this is a close case and this Court finds compelling the logic of Beverly, this Court is constrained to find that the good faith exception applies in this case, and the CSLI will not be suppressed even though obtained without a warrant. Law enforcement officers followed the procedure set out by a statute and complied with Sixth Circuit law at the time. Krull and Davis establish that the good faith exception applies in such circumstances.” United States v. Sands, 2019 U.S. Dist. LEXIS 72228 (S.D. Ohio Apr. 30, 2019).*