In a brief order, the United States District Court for the Northern District of California suppressed the use of cell phone evidence in a brief order that detailed misconduct by agents in the procurement of cell phone evidence.
The Court also held that the use of a cell-site simulator to locate one of the defendants violated the Fourth Amendment. In doing so, the court noted that the use of a cell-site simulator requires a warrant, citing a number of cases including Carpenter.
The Court, looking at the number of errors by law enforcement as well as the nature of them, refused to invoke the good faith exception.
The case is United States v. Artis, 2018 U.S. Dist. LEXIS 112696 (July 3)
There is a companion decision worth reviewing to give this matter context. It mentions Carpenter but that case plays no role in the decision.
That case is United States v. Artis, 2018 U.S. Dist. LEXIS 112697 (July 3)