M.D.Fla.: CSLI order 3½ months before Carpenter was valid under GFE; officers not expected to know what SCOTUS will do

CSLI order issued 3½ months before Carpenter was valid under good faith exception. Officers were not expected to know what SCOTUS would do. United States v. Turner, 2019 U.S. Dist. LEXIS 81011 (M.D. Fla. May 14, 2019).

The law supported the state’s exigent circumstances claim for defendant’s warrantless blood draw at the time it happened, so the good faith exception applies. Hamrick v. State, 2019 S.C. LEXIS 42 (May 15, 2019).*

Defendant’s post-conviction search claim says nothing about why it wasn’t raised on direct appeal, so it is defaulted. State v. Hall, 2019-Ohio-1848, 2019 Ohio App. LEXIS 1925 (11th Dist. May 13, 2019).*

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