Assuming without deciding that a state tracking warrant couldn’t be tracked outside the state, the exclusionary rule would not be applied because the officers were all clearly operating in good faith. Moreover, defendant’s committing yet another bank robbery while he was being tailed broke any causal connection. United States v. Brewer, 2019 U.S. App. LEXIS 25822 (9th Cir. Aug. 27, 2019).
Defendant should have raised his Carpenter issue with its cert grant. In a post-trial motion was waiver. United States v. Barberr, 2019 U.S. App. LEXIS 25849 (7th Cir. Aug. 27, 2019).