One co-conspirator has no standing in GPS tracking of his co-conspirator’s cell phone. The officers also had probable cause to search their car based on: knowledge they were cell phone store burglars, a Snapchat video with defendants having numerous cell phones in new packaging, tracking their car to Oklahoma, a burglary occurring where the phone was with a burglarized store video matching their description, and then crossing state lines heading back to Missouri. United States v. Kirkendoll, 2021 U.S. Dist. LEXIS 31708 (W.D. Mo. Feb. 19, 2021).
The question for child pornography is whether there is probable cause and not whether the officers could have tried some other less invasive approach first. Moreover, the good faith exception applies. United States v. Bryant, 2021 U.S. Dist. LEXIS 31704 (S.D. Ohio Feb. 21, 2021).*