DE: Carpenter doesn’t apply to specific cell tower dumps obtained by SW

Carpenter doesn’t apply to specific cell tower dumps obtained by search warrant. “The warrants present in this case are not a top-to-bottom search of any and all stored data of the digital contents of the devices and ‘any other information/data pertinent to this investigation’ belonging to the defendant like the one in Taylor. [Taylor v. State, 2021 WL 4095672, at 8 (Del. 2021)] A distinction must be made between a warrant for an individual’s data found on their devices and cell tower dumps, like the Cell Tower Warrants. The search in contention is not one of all data of an individual’s devices so a lower standard should be warranted. However, even if this Court chooses to look at the cell tower dumps under the lens of Taylor, there is not similar broad language to render the Cell Tower Warrants unconstitutional as the warrant in Taylor .” State v. Hudson, 2021 Del. Super. LEXIS 670 (Nov. 23, 2021).

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