D.Ariz.: A cell phone tower dump of a two-hour span is not a “Fourth Amendment event”

A cell phone tower dump of a two-hour span is not a “Fourth Amendment event.” Even if it was, the good faith exception applies. United States v. Pricop, 2025 U.S. Dist. LEXIS 55939 (D. Ariz. Mar. 25, 2025):

The data produced in a cell tower dump is qualitatively different from the data produced by continuous CSLI monitoring. The Tower Dump Orders gave ATF access to, for periods of three and a half hours or less, a list of the devices that connected to the towers, which tower the devices connected to, and length of the communication. Doc. 41 at 2. This is different from the continuous monitoring of a single person’s location for multiple days at issue in Carpenter. Carpenter required a warrant for CSLI data because monitoring “the whole” of an individual’s physical movement is highly invasive. Because the tower dumps here did not allow ATF access to “the whole” of anyone’s movement, or anything close, the Court will not extend Carpenter to require probable cause for tower dumps.