CA6 applies GFE to Carpenter on remand, and he still loses

The SCA was the law prior to Carpenter, so the good faith exception applies. From the date of Carpenter, the Fourth Amendment applies: “Carpenter II confirmed that the SCA does not immunize a government officer’s collection of CSLI from the safeguards of the Fourth Amendment. Moving forward, traditional Fourth Amendment principles will replace reflexive or mechanical use of § 2703(d). The government must either get a warrant or rely on a recognized exception to the warrant requirement.” United States v. Carpenter, 926 F.3d 313 (6th Cir. June 11, 2019), rehearing granted on sentence on other grounds, United States v. Carpenter, 2019 U.S. App. LEXIS 37721 (6th Cir. Dec. 19, 2019):*

Rodriguez lost on remand, too.