Two months of CSLI seven years before Carpenter was subject to the good faith exception. United States v. Pritchard, 2020 U.S. App. LEXIS 21030 (6th Cir. July 7, 2020)* (a valiant try based on the circuit’s Warshak email decision).
“What is more relevant than whether Mr. Atlas violated the statute is whether Deputy Zide reasonably believed that he did. This is because ‘the ultimate touchstone of the Fourth Amendment is “reasonableness.”’ Heien v. North Carolina” … “While this Court is not convinced that Deputy Zide’s interpretation of the statute was correct, for purposes of the joint Motion to Suppress, what matters is whether his interpretation was reasonable. It was.” United States v. Atlas, 2020 U.S. Dist. LEXIS 118739 (S.D. Ohio July 7, 2020).*