Solis and Diaz — SJC Upholds Delayed Cell Phone Warrants
The Massachusetts SJC held that 109- and 123-day delays in seeking cell phone search warrants were reasonable under article 14’s totality-of-the-circumstances test.
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Privacy
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State v. Eberhart — GPS Data from Private Bond Company Requires Warrant; Admission Harmless
The South Carolina Court of Appeals held that a criminal defendant wearing a private bond company’s GPS ankle monitor retains a reasonable expectation of privacy in that location data under the Fourth Amendment and Article I, Section 10 of the South Carolina Constitution, requiring a warrant; though the trial court erred in admitting the warrantlessly obtained GPS data, the error was harmless given the victim’s in-court identification, the stolen moped evidence, and the victim’s debit card found on the defendant at arrest.