PA: Police getting SW for CSLI they already had after Carpenter was reasonable

Carpenter was decided three weeks before defendant’s trial. The state then sought a search warrant to supplement its having already obtained the CSLI. Defendant’s motion to suppress on the eve of trial was denied. The search warrant was adequate for probable cause [and attenuation], and the search is not suppressed. Commonwealth v. Burton, 2020 PA Super 157, 2020 Pa. Super. LEXIS 545 (July 6, 2020).

Defendant’s 2255 claim that the probable cause for the search warrant for his house is denied because he only offers his self-serving claim that the officers made up the two controlled buys, one 24 hours before the warrant issued. United States v. Fox, 2020 U.S. Dist. LEXIS 117696 (S.D. Tex. July 6, 2020).*

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