N.D.Ill.: Obtaining mobile IP address not governed by Carpenter

In a child exploitation case, the government admitted that the state search warrant in another state wasn’t as detailed as they’d have done, but it still showed probable cause and was supported by the good faith exception. The mobile IP address for defendant’s cell phone can provide some location information, but it is nowhere near what Carpenter involved. This is much more like United States v. Soybel, 3 F.4th 584 (7th Cir. 2021), and it was mere third party information. United States v. Barnett, 2023 U.S. Dist. LEXIS 22608 (N.D. Ill. Feb. 10, 2023).

During a knock-and-talk, defendant consented to entry to look for her passport. United States v. Lopez, 2023 U.S. App. LEXIS 3229 (5th Cir. Feb. 9, 2023).*

The inventory was valid despite some investigatory motive. “In sum, Officer Burr’s statements and/or subjective motives have no bearing on the constitutionality of the search; even if he had some subjective investigatory intent (which the Court does not find), the inventory search would remain valid, as law enforcement did no more than they were objectively authorized and legally permitted to do.” United States v. Franklin, 2023 U.S. Dist. LEXIS 22585 (E.D. Tex. Jan. 20, 2023).*

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