A tower dump warrant is an issue left open in Carpenter, 585 U.S. at 316, and the police effort here was valid under the good faith exception. United States v. Campbell, 2026 U.S. Dist. LEXIS 146360 (E.D.N.Y. June 30, 2026):<\/p>\n\n\n\n\n\n\n\n
\n\nIndeed, there was little judicial precedent that the postal inspectors could turn to for guidance at the time. The Supreme Court had expressly declined to voice a view as to the constitutionality of tower dumps in Carpenter. Carpenter, 585 U.S. at 316. In the years that followed, lower courts were slow to pick up the slack, and decisions on the legality of tower dumps were few and far between. In fact, prior to the time the warrant challenged here was granted, there was only one (unpublished) decision in the Second Circuit on this issue\u2014and, on facts analogous to those in this case, it had flatly rejected the defendant’s challenge to the tower dump warrant. See United States v. Morris, No. 20-CR-100-RJA-JJM, 2022 WL 1651408, at *10-11 (W.D.N.Y. Apr. 12, 2022), report and recommendation adopted, 2022 WL 1645261 (W.D.N.Y. May 24, 2022). Moreover, out-of-circuit decisions at the time were, for the most part, fully in accord. See, e.g., Matter of Search of Info. Associated with Cellular Tel. Towers Providing Serv. To [Redacted] Stored at Premises Controlled by Verizon Wireless, 616 F. Supp. 3d 1 (D.D.C. 2022) (granting warrant application); Matter of Tower Dump Data for Sex Trafficking Investigation, No. 23 M 87, 2023 WL 1779775 (N.D. Ill. Feb. 6, 2023) (same); United States v. James, 3 F.4th 1102 (8th Cir. 2021) (affirming denial of motion to suppress). With such a track record of success in the courts, the postal inspectors in this case can hardly be faulted for believing themselves to be in the clear when they made their own request for tower dump data.<\/p>\n\n\n\n
With that groundwork in place, each of Campbell’s arguments for applying the carve-outs to the good-faith exception can now be disposed of in turn. To begin, the tower dump warrant application was not so lacking in indicia of probable cause, or so “bare bones,” as to render reliance upon the warrant unreasonable. Proving that warrant applications are “bare bones,” such that “they are totally devoid of factual circumstances to support conclusory allegations,” is “a very difficult threshold” to cross\u2014and Campbell has not succeeded in his quest to do so. Jones, 43 F.4th at 112 (first quoting Clark, 638 F.3d at 103; and then quoting United States v. Falso, 544 F.3d 110, 128 n.24 (2d Cir. 2008)) (internal quotation marks omitted).<\/p>\n<\/blockquote>\n<\/blockquote>\n","protected":false},"excerpt":{"rendered":"
A tower dump warrant is an issue left open in Carpenter, 585 U.S. at 316, and the police effort here was valid under the good faith exception. United States v. Campbell, 2026 U.S. Dist. LEXIS 146360 (E.D.N.Y. June 30, 2026):<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[84,11],"tags":[],"class_list":["post-64360","post","type-post","status-publish","format-standard","hentry","category-cell-site-location-information","category-good-faith-exception"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64360","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=64360"}],"version-history":[{"count":1,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64360\/revisions"}],"predecessor-version":[{"id":64361,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64360\/revisions\/64361"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=64360"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=64360"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=64360"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}