The collective knowledge doctrine doesn’t require that the officers actually share the information. United States v. Devaugh, 2019 U.S. Dist. LEXIS 196059 (D.D.C. Nov. 12, 2019).
The use of a “court ordered subpoena” apparently not issued on probable cause was common in the jurisdiction prior to Carpenter, and there was no binding authority that was unconstitutional. Therefore, the CSLI would not be suppressed. State v. Tyler, 2019-Ohio-4661, 2019 Ohio App. LEXIS 4708 (9th Cir. Nov. 13, 2019).
The officer lacked reasonable suspicion to stop defendant that he was about to commit DUI. State v. Kreis, 365 Ore. 659 (Nov. 7, 2019).*