Defendant was long under surveillance for drug deals, and a search warrant was obtained for his person and premises. It did not include his vehicles. The search authorization did not encompass his vehicle on the premises outside the house, and there was no specific probable cause for the vehicle. People v. Gordon, 2021 NY Slip Op 01093, 2021 N.Y. LEXIS 102 (Feb. 18, 2021) (see § 56.09 “Place” as including outbuildings and vehicles).
Historical CSLI validly recovered pre-Carpenter was protected by the good faith exception. United States v. Kent, 2021 U.S. Dist. LEXIS 30291 (N.D.Ga. Jan. 28, 2021).*