MD & NY2: Court ordered GPS tracking satisfied warrant requirement

Court ordered GPS tracking of a vehicle for up to 30 days under state statute satisfied the warrant requirement for its showing of probable cause before a neutral and detached magistrate. Whittington v. State, 2020 Md. App. LEXIS 621 (July 1, 2020).

CSLI obtained by court order satisfied the warrant requirement, even if the issue was preserved for appellate review, which it’s not. People v. Grant, 2020 NY Slip Op 03674, 2020 N.Y. App. Div. LEXIS 3746 (2d Dept. July 1, 2020).

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