E.D.Mo.: PC shown for def’s CSLI at time of murder

The affidavit for search warrant for CSLI for defendant’s phone was issued with probable cause. Defendant’s phone allegedly talked to the murder victim shortly before the murder, and it was reasonable to attempt to determine where the defendant’s phone was at the time of the murder. United States v. Johnson, 2019 U.S. Dist. LEXIS 65896 (E.D. Mo. Mar. 11, 2019), adopted, 2019 U.S. Dist. LEXIS 64774 (E.D. Mo. Apr. 16, 2019).

A package in the mail was intercepted at the border on a truck and it contained Xanax hidden in vitamins. Further investigation by Homeland Security revealed many similar packages sent in the past. The package and the past history was a valid basis for an anticipatory warrant. United States v. Green, 2019 U.S. Dist. LEXIS 64953 (D. Mont. Apr. 16, 2019).*

Carpenter doesn’t apply retroactively, and, even if it did, the good faith exception applies. United States v. Henderson, 2019 U.S. Dist. LEXIS 64918 (W.D. Tenn. Apr. 16, 2019).*

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