MA: Two on CSLI standing

Defendant had standing to challenge CSLI used to track his car when he was a passenger and the driver was using his cell phone. Commonwealth v. Fredericq, 482 Mass. 70 (Apr. 24, 2019).

Defendant did not have standing for a motion to suppress to challenge the search of a friend’s cell phone, as although defendant was with the friend when her location was searched by pinging, the period of the search, less than two hours, was not sufficiently significant to allow defendant standing in the cell phone. Commonwealth v. Lugo, 482 Mass. 94 (Apr. 24, 2019).