There was probable cause to arrest, and that also justified the extension of the stop. The actual arrest doesn’t have to happen during the extension. United States v. Phillips, 2019 U.S. Dist. LEXIS 89962 (D. Mont. April 12, 2019), adopted, 2019 U.S. Dist. LEXIS 89104 (D. Mont. May 28, 2019).
Defense counsel wasn’t ineffective for not filing a motion to suppress CSLI four years before Carpenter. “Although Key may wish that his attorney had been more prescient, ‘attorneys are not required to predict changes in the law.’” United States v. Key, 2019 U.S. Dist. LEXIS 91498 (S.D. N.Y. May 31, 2019).*