CA9: Private search of CSLI made it admissible in admin proceeding

The Washington State Department of Labor and Industries received information from whistleblowers of cell site location information the defendant business collected to show alleged violations of state law. This was a private search, and Carpenter is not implicated. Kleiser v. Chavez, 2022 U.S. App. LEXIS 33918 (9th Cir. Dec. 9, 2022).

The search warrant was executed in good faith. It was the same as a prior affidavit for warrant, and it was based on the same facts as the complaint for defendant’s arrest. United States v. Carrasco, 2022 U.S. Dist. LEXIS 221931 (S.D.N.Y. Dec. 8, 2022).*

The FBI’s standardized procedure for vehicle inventory was testified to. The fact one form was used for two purposes doesn’t matter. There is no showing of an investigative motive for the search. United States v. Farah, 2022 U.S. Dist. LEXIS 221984 (D. Minn. Dec. 9, 2022).*

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