Narrative Opinion Summary
In this case, the court denied three government applications under 18 U.S.C. § 2703(d) for historical cell site location information (CSLI) due to internal inconsistencies and lack of relevance to ongoing investigations. The applications, submitted in March and renewed in September 2013, sought CSLI from different cellphone companies for varying durations related to crimes occurring from late 2012 to early 2013. The court found that the requests failed to comply with the specificity requirements of § 2703(d), as they lacked specific and articulable facts demonstrating the relevance and materiality of the CSLI to the investigations. The broad nature of the requests, which were not limited to call times, raised Fourth Amendment concerns as they could potentially allow comprehensive tracking of a phone's location. The court emphasized the government's burden of proof in justifying the necessity for such extensive CSLI and criticized the use of boilerplate language. Although the applications were denied without prejudice, the court allowed the government to refine its requests and resubmit with additional factual support. The opinion was made public, but underlying documents remained sealed to protect ongoing investigations, and the court instructed the government to correct errors in provider references and clarify its collaboration with cellphone companies.
Legal Issues Addressed
Burden of Proof in Demonstrating Necessity of CSLIsubscribe to see similar legal issues
Application: The court emphasized that the government bears the burden of proof in demonstrating the necessity of the requested CSLI, which was not met.
Reasoning: The Court emphasizes that the government bears the burden of proof in demonstrating the necessity of the requested CSLI, which it has failed to do.
Fourth Amendment Concerns in CSLI Requestssubscribe to see similar legal issues
Application: The court highlighted potential Fourth Amendment issues due to the broad nature of the CSLI request, which could lead to comprehensive tracking of a phone's location.
Reasoning: The precision and frequency of the CSLI could infringe on protected areas, as established in precedents like United States v. Karo and Kyllo v. United States.
Limitations on Scope and Timeframe of CSLI Requestssubscribe to see similar legal issues
Application: Requests for CSLI must be limited to specific timeframes relevant to the investigation, which was not adequately demonstrated in the government's applications.
Reasoning: The government seeks to obtain cell site location information (CSLI) related to specific crimes that occur during set times of day. However, the request for CSLI that is not limited to these timeframes lacks the necessary 'specific and articulable facts' to establish its relevance and materiality under § 2703(d).
Need for Accurate and Consistent Language in CSLI Applicationssubscribe to see similar legal issues
Application: Inconsistencies and boilerplate language in the applications led to their denial, and the government is urged to use precise language.
Reasoning: The initial application was submitted on March 5, 2013, related to crimes from late 2012 to early 2013, but was denied for relying on outdated language and failing to address legal precedents.
Requirement for Specificity in CSLI Requests under 18 U.S.C. § 2703(d)subscribe to see similar legal issues
Application: The government must present specific facts to justify the relevance and materiality of CSLI to an ongoing investigation, which it failed to do in this case.
Reasoning: Under § 2703(d), the government is required to present specific facts demonstrating that the CSLI sought is relevant and material to an ongoing investigation.