Case5:15-xr-90304-HRL Document30 Filed07/29/15 Page44 of 46
United States District Court
Northern District of California
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In short, the government has two basic options for obtaining “a record or other information
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pertaining to a subscriber to or customer of [a provider of electronic communication service],”
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such as historical CSLI. 18 U.S.C. § 2703(c)(1). Those options are: (1) a search warrant
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supported by probable cause, id § 2703(c)(1)(A); or (2) a court order under § 2703(d) based on
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specific and articulable facts showing that the information sought is relevant and material to an
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ongoing criminal investigation, id. § 2703(c)(1)(B). It is less than clear why Congress created two
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different paths. Perhaps, as Judge Lloyd suggests, Congress did so out of “recognition that some
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information should be accorded a higher level of protection from disclosure than other
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information.” ECF No. 2 at 4. In any event, all the Court holds today is that when the
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government seeks to obtain historical CSLI from a cellular service provider, the Fourth
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Amendment requires that the government obtain a warrant. To do so, the government need only
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follow the procedures already outlined in § 2703(c)(1)(A).
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The language of § 2703(d) is not to the contrary. Section 2703(d) provides that a “court
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order for disclosure under subsection (b) or (c) may be issued by any court that is a court of
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competent jurisdiction and shall issue only if ” the specific and articulable facts standard is met.
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18 U.S.C. § 2703(d) (emphases added). If, as the government contends, the language of § 2703(d)
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requires a magistrate judge to issue a court order so long as the government has met the specific
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and articulable facts standard, a standard lower than probable cause, then § 2703(d) of the SCA
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would be unconstitutional as applied to historical CSLI. See Gov’t Reply at 12.
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This Court, however, finds that the Third Circuit’s interpretation of § 2703(d) is an
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acceptable construction of the provision such that it need not be invalidated. See Third Circuit
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Opinion, 620 F.3d at 315-17. The Third Circuit held that § 2703(d) provides magistrate judges
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with discretion to require a warrant on a showing of probable cause because that provision begins
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with the permissive language “may be issued” and uses the phrase “only if,” rather than simply
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“if.” Id. at 315. The Third Circuit found that if issuing an order under § 2703(d) were not
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discretionary, “the word ‘only’ would be superfluous.” Id. This is so, the Third Circuit reasoned,
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Case No. 15-XR-90304-HRL-1(LHK)
ORDER AFFIRMING DENIAL OF APPLICATION FOR HISTORICAL CELL SITE LOCATION
INFORMATION
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