Historical cell site location data limited to 20 days in an attempt to link defendant to a home invasion robbery was reasonable. (Also, defendant who was not the subscriber of a cell phone had no standing to challenge obtaining historical cell site location data.) United States v. Wilson, 2013 U.S. Dist. LEXIS 37783 (N.D. Ga. February 20, 2013), adopted 2013 U.S. Dist. LEXIS 37320 (N.D. Ga. Mar. 19, 2013):<\/p>\n
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In this case, the records that the government relies upon are limited in time frame to twenty-one days prior to issuance of the order \u2014 a relatively short time frame for “cumulation” to occur, even if the cumulative effect made a difference. Thus, for the reasons stated above, the undersigned concludes, as did the Court in Graham [846 F. Supp. 2d 384 (D. Md. 2012)], that the records at issue were business records kept in the ordinary course of business by the third-party cellular service provider. This information was derived from information voluntarily provided to the provider when the user made or received a call. As such, Defendant has no legitimate expectation of privacy in those records, and the Fourth Amendment was not violated in this case, even if Defendant had threshold “standing” to complain about the acquisition of the records.<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"
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