E.D.N.Y.: To get CSLI, there must be some showing the phone was involved in the crime

Just saying that criminals usually have their cell phones on them is not sufficient for probable cause. Something tying the phone to the crime, however, is enough. Here it was text messages.
United States v. Rutledge, 2024 U.S. Dist. LEXIS 76534 (E.D.N.Y. Apr. 26, 2024).

The Rooker-Feldman doctrine applies whether the party was the state court defendant or plaintiff. Bowen v. Gordon, 2024 U.S. Dist. LEXIS 76171 (N.D.N.Y. Apr. 26, 2024).*

Qualified immunity applies: “Viewing the facts in plaintiff’s favor, defendant officers reasonably believed that plaintiff’s arrest for obstructing official business was lawful.” One Eye El-Bey v. Wallace, 2024 U.S. Dist. LEXIS 76508 (S.D. Ohio Apr. 25, 2024).*

The court grants defendant’s motion to suppress, and it’s up to the Government to persuade the Eleventh Circuit the community caretaking function should apply. United States v. Lewis, 2024 U.S. Dist. LEXIS 76519 (N.D. Ala. Apr. 26, 2024).*

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