U.S. Dist. Ct. for M. D. Penn. declines to apply Carpenter because good faith exception and a previous finding of Probable Cause

The United States District Court for the Middle District of Pennsylvania decided against a defendant invoking Carpenter in the context of a third motion to reconsider the denial of a motion to suppress of CSLI based on the new decision in Carpenter mainly because the order was supported by a finding of probable cause.

The Court based its decision based on both the good faith exception and because the judge who issued the order explicitly found that there was probable cause.

The case is United States v. Coles, 2018 U.S. Dist. LEXIS 129617, 2018 WL 3659934 (M.D. Penn.) (August 2).

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