GA: Even if pre-Carpenter CSLI was error [not] it was harmless error

Even if the good faith exception doesn’t admit CSLI before Carpenter, it’s harmless error. “At the time of Hill’s 2014 trial, controlling precedent held that a search warrant was not required to obtain cell site location data.” “Here, the cell site location data was cumulative of properly admitted evidence that placed Hill at the murder scene, including the testimony of the surviving victim, the testimony of Hill’s accomplice, and Hill’s own admitted pretrial statement, and the evidence of his guilt was overwhelming. The State carried its burden of showing that any error in admitting the evidence did not contribute to the verdict.” Hill v. State, 2020 Ga. LEXIS 668 (Sept. 28, 2020).

“The traffic stop here was valid under Terry. The officer received a description of the getaway vehicle from dispatch. He then observed a vehicle matching that description less than a minute from the time he received the description and less than a mile from the reported crime scene.” Lumpkin v. State, 2020 Ga. LEXIS 669 (Sept. 28, 2020).*