E.D.N.Y.: Rental car GPS data not comparable to CSLI; it’s just third-party information

Rental car location tracking is significantly different from CSLI. It is purely third-party information. Moreover, the rental car company consented to the taking of the information. United States v. Brown, 2022 U.S. Dist. LEXIS 166119 (E.D.N.Y. Sept. 14, 2022).

The officer’s interpretation of the statute was reasonable even if mistaken, so Heien applies and there is no application of the exclusionary rule. Knapp v. State, 2022 Fla. App. LEXIS 6250 (Fla. 1st DCA Sept 14, 2022).

The stop for a traffic offense was reasonable, and reasonable suspicion developed on the totality to extend it. United States v. Betts, 2022 U.S. Dist. LEXIS 166214 (S.D. Iowa Aug. 8, 2022).*

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