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Administrative Law Keyed to Mawshaw
Carpenter v. United States
Citation:
138 S. Ct. 2206 (2018)Facts
In 2011, police arrested four men suspected of robbing a series of RadioShack and T-Mobile stores in Michigan and Ohio. One suspect identified Timothy Carpenter as an accomplice and provided his cell phone number. Based on this information, prosecutors obtained court orders under the Stored Communications Act to access Carpenter’s cell-site location records from his wireless carriers, MetroPCS and Sprint. The government acquired 12,898 location data points cataloging Carpenter’s movements over 127 days—an average of 101 data points per day. These records placed Carpenter’s phone near four of the robbery locations at the time of the crimes. Carpenter moved to suppress this evidence, arguing that the government’s warrantless acquisition of these records violated his Fourth Amendment rights. The motion was denied, and Carpenter was convicted of robbery and firearms offenses based partly on the cell-site evidence. The Sixth Circuit affirmed, holding that Carpenter had no reasonable expectation of privacy in information he voluntarily shared with his wireless carriers.
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