Case5:15-xr-90304-HRL Document30 Filed07/29/15 Page27 of 46
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Florida Supreme Court, citing the Third Circuit’s opinion, concluded that the third-party doctrine
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did not control: “Simply because the cell phone user knows or should know that his cell phone
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gives off signals that enable the service provider to detect its location for call routing purposes,
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and which enable cell phone applications to operate for navigation, weather reporting, and other
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purposes, does not mean that the user is consenting to use of that location information by third
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parties for any other unrelated purposes.” Tracey, 152 So. 3d at 522. One court, moreover, found
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it “difficult to understand how the user ‘voluntarily’ expose[s] [CSLI] to a third party” where the
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government seeks “information—essentially, continuous pinging—that is not collected as a
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necessary part of cellular phone service, nor generated by the customer in placing or receiving a
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United States District Court
Northern District of California
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call.” In re Application, 849 F. Supp. 2d at 539 n.6.
Furthermore, the mere fact that historical CSLI is a record maintained by a cellular service
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provider, and not kept by the user, does not defeat the user’s expectation of privacy in what that
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information reveals—namely, the user’s location at any moment her cell phone communicates
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with a cell tower. As the Ninth Circuit has explained, “it is clear that neither ownership nor
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possession is a necessary or sufficient determinant of the legitimacy of one’s expectation of
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privacy.” DeMassa v. Nunez, 770 F.2d 1505, 1507 (9th Cir. 1985).
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Indeed, in Ferguson v. City of Charleston, 532 U.S. 67, 76-78 (2001), the U.S. Supreme
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Court held that law enforcement needed a warrant to obtain drug testing results from the urine of
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pregnant women, even though the results were kept by a third party state hospital. The Ferguson
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Court so held because “[t]he reasonable expectation of privacy enjoyed by the typical patient
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Commc’n Serv. to Disclose Records to the Gov’t, 534 F. Supp. 2d 585, 615 (W.D. Pa. 2008)
(concluding that “CSLI is not ‘voluntarily and knowingly’ conveyed by cell phone users”),
vacated on other grounds sub nom. Third Circuit Opinion, 620 F.3d 304 (3d Cir. 2010). Judge
Lenihan’s opinion was notable, the Third Circuit explained, because it “was joined by the other
magistrate judges in that district.” Third Circuit Opinion, 620 F.3d at 308. The Third Circuit
continued: “This is unique in the author’s experience of more than three decades on this court and
demonstrates the impressive level of support Magistrate Judge Lenihan’s opinion has among her
colleagues who, after all, routinely issue warrants authorizing searches and production of
documents.” Id.
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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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