Jurisdiction for search warrants in federal court is over the offense. Thus, a USMJ could sign a search warrant for a Dropbox account in California under the SCA. United States v. Hopkins, 2020 U.S. Dist. LEXIS 173418 (D. Kan. Sept. 22, 2020).
Facebook’s responding to a search warrant for records is private action as to it. “The gravamen of Plaintiff’s claims against Defendant Facebook is that Facebook failed to protect his data, which allowed third parties to access and misuse his personal information and the authorities to surveil him. (See SAC at 5-6; FAC at 6.) But Plaintiff has not identified a cause of action that could cover this injury and, as discussed, he has not plausibly alleged that the alleged third-party conduct — at least as it relates to Defendant Brooks and Detective Cerone — in fact occurred.” Griffin v. Facebook, 2020 U.S. Dist. LEXIS 173499 (S.D. N.Y. Sept. 21, 2020).*