LA5: CSLI obtained by subpoena 16 months before Carpenter subject to GFE

The state obtained defendant’s CSLI 16 months before Carpenter with a subpoena duces tecum. Under the Davis v. United States good faith exception, the exclusionary rule should not apply. State v. Davis, 2019 La. App. LEXIS 627 (La. App. 5 Cir. Apr. 10, 2019).*

Cell phone records in Mexico were third party records not subject to the Fourth Amendment. “Moreover, the SCA does not apply extraterritorially.” United States v. Lugo, 2019 U.S. Dist. LEXIS 61704 (E.D. Tex. Mar. 27, 2019),* adopted 2019 U.S. Dist. LEXIS 61180 (E.D. Tex. Apr. 10, 2019).*

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