The use of an CPD “investigative alert” to arrest defendant was unreasonable and a violation of the Fourth Amendment (but harmless on the totality). People v. Smith, 2022 IL App (1st) 190691, 2022 Ill. App. LEXIS 329 (July 18, 2022).
Defendants were arrested on the high seas by the Coast Guard near the Galapagos Islands off Ecuador. They were transferred to Long Beach then San Diego, but Miami was closer. It took 23 days to get them to court under Rule 5. Their motion to dismiss the indictment for unreasonable delay was properly denied. They don’t really even contend it was that unreasonable. United States v. Dominguez-Caicedo, 2022 U.S. App. LEXIS 19723 (9th Cir. July 18, 2022).*
Pre-Carpenter CSLI was lawfully obtained under the SCA and with good faith. United States v. Scarfo, 2022 U.S. App. LEXIS 19690 (3d Cir. July 15, 2022).*