4th Circuit again denies Carpenter claim based on good faith exception.

In a brief Per Curiam opinion, the Fourth Circuit affirmed a conviction which included the denial of a motion to suppress based on cell site location information. They did so relying on the good faith doctrine, citing United States v. Chavez, 894 F.3d 593, 608 (4th Cir. 2018), petition for cert. docketed, U.S.L.W. , (U.S. Aug. 9, 2018) (Previously featured on this blog on August 13).

This ruling is based on more sound footing in my mind because there was 4th Circuit precedent prior to Carpenter ruling that these orders did not require warrants (compared to e.g., the 7th Circuit decision in United States v. Curtis).

The case is United States v. Christian, 2018 U.S. App. LEXIS 25580, 2018 WL 4293340 (4th Cir.) (Sept. 10).

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