As you probably know, Facebook had a huge security breach as of late. A recent piece in the New York Times indicates that this includes your location data.
Here is a link to the piece:
A search by law enforcement data therefore has tremendous implications vis a vis Carpenter. If hackers can get this information, then there’s every reason to believe law enforcement will want this information to prosecute a defendant. The question then becomes whether acquiring such data comports with the Fourth Amendment.