Pre-Carpenter CSLI was in good faith

The CSLI order here pre-dated Carpenter, and it was based on probable cause. Since Carpenter wasn’t retroactive, the motion to suppress is denied. United States v. Stamat, 2021 U.S. Dist. LEXIS 14268 (D.Minn. Jan. 26, 2021).*

Defendant’s CSLI was obtained three years before Carpenter and his case was final well before it was decided. The good faith exception applies in any event. Davis v. United States, 2021 U.S. App. LEXIS 2191 (11th Cir. Jan. 26, 2021).*

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