The defendant was on parole in California. As part of his parole, he consented to warrantless, suspicionless searches of his person, residence, and any property under his control.
He challenged the warrantless searches of: (1) the trunk of his car; (2) the use of a GPS tracking device on his car; and (3) his CSLI (cell site location information).
The Ninth Circuit found the search of the trunk and the use of the GPS tracker were permissible based on the defendant's parole status.
As to the CSLI, the Court did not decide the constitutional issue. Instead, it found the good faith exception applied. At the time of the CSLI search, Carpenter had not yet been decided. Thus, the Court concluded the government relied in good faith on the then-applicable authorizing statute, the Stored Communications Act.
