DE: Def was subjected to a warrantless CSLI search in 2016, and Carpenter came before judgment was entered; CSLI was harmless BRD here

Defendant was the subject of a CSLI order issued without probable cause in 2016 to connect him to a murder. Carpenter was issued before he was sentenced and thus applies to his case. [Without even discussing the good faith exception exception,] The court finds the CSLI information harmless beyond reasonable doubt on the trial record. Motion for new trial denied. State v. Waters, 2019 Del. Super. LEXIS 283 (June 13, 2019).

DEA agents were surveilling defendants throughout the day. When they stopped their minivan, they had plenty of reason to know they were inside. United States v. Guzman, 2019 U.S. App. LEXIS 17743 (8th Cir. June 13, 2019).*

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