CSLI obtained by court order, but without showing probable cause, nearly three years before Carpenter was all in good faith. Watson v. State, 2020 Ala. Crim. App. LEXIS 4 (Jan. 10, 2020).
Defendant’s ineffective assistance of counsel claim against counsel for not challenging probable cause fails because there clearly was probable cause based on a wiretap. Brady v. United States, 2019 U.S. Dist. LEXIS 224535 (M.D. N.C. Dec. 11, 2019),* adopted, 2020 U.S. Dist. LEXIS 2716 (M.D. N.C. Jan. 8, 2020).*
Defendant’s challenge to the search warrant fails where observations made during a valid protective sweep were included in the warrant application. (The concurrence finds no standing.) State v. Rosemond, 2019-Ohio-5356, 2019 Ohio App. LEXIS 5517 (1st Dist. Dec. 27, 2019).*