Marcus Zanders v. State of Indiana, 118 N.E.3d 736

Two armed, masked liquor-store robberies in Dearborn County (Jan 31 and Feb 6, 2015) with similar modus operandi; both involved theft of cash, phones, and tequila.
J & J clerk received an Ohio phone call shortly before the Feb 6 robbery; that number was linked to a Facebook profile for Marcus Zanders that posted photos/videos of cash and tequila after the robberies.
Police submitted an emergency request to Sprint and obtained 30 days of historical cell-site location information (CSLI) for that number ~16.5 hours after the Feb 6 robbery; Sprint produced the CSLI before officers obtained search warrants for Zanders’s residences.
Searches of Zanders’s mother’s and brother’s residences (pursuant to warrants) yielded clothing, cash, bottles of tequila, a 40-caliber handgun, and phones consistent with the robberies; Zanders was arrested with the phone linked to the Facebook account.
At trial the court admitted CSLI and related testimony over Zanders’s objection; jury convicted him of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm.
After the U.S. Supreme Court decided Carpenter v. United States (holding historical CSLI is generally a Fourth Amendment search), the Supreme Court vacated and remanded this case for reconsideration in light of Carpenter.

Issue	State's Argument (Plaintiff)	Zanders' Argument (Defendant)	Held
Was government acquisition of 30 days of CSLI a Fourth Amendment search?	Not a search under the third-party doctrine; alternatively, exigent circumstances justified access.	Carpenter controls: accessing historical CSLI is a Fourth Amendment search.	Accessing Zanders’s 30 days of CSLI was a Fourth Amendment search under Carpenter.
Did exigent circumstances justify the warrantless CSLI acquisition?	Yes; officers faced an armed-robber exigency and acted to locate him quickly.	No; exigency did not exist to excuse the warrant requirement.	Court did not decide the exigency issue; disposition rests on harmless-error analysis.
If CSLI was obtained unlawfully, should evidence from the residence searches be excluded as fruit of the poisonous tree?	Warrant-based residence-search evidence admissible; officers acted in objective good faith relying on warrants.	Warrants were tainted by CSLI and thus evidence should be excluded.	Good-faith exception to exclusionary rule applied; residence-search evidence remained admissible.
If CSLI admission was error, was it harmless beyond a reasonable doubt?	Yes; non-CSLI evidence overwhelming, CSLI was cumulative and limited, and defense cross-examined CSLI.	No; CSLI was important to establishing probable cause and identity.	Admission of CSLI (if error) was harmless beyond a reasonable doubt; convictions affirmed.

Carpenter v. United States, 138 S. Ct. 2206 (2018) (historical CSLI generally implicates Fourth Amendment privacy)
Smith v. Maryland, 442 U.S. 735 (1979) (third-party doctrine for dialed-number/pen-register records)
United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to the exclusionary rule)
Chapman v. California, 386 U.S. 18 (1967) (harmless-error standard for constitutional errors)
Delaware v. Van Arsdall, 475 U.S. 673 (1986) (harmless-error framework and inquiry into effect of erroneous evidence)
Hudson v. Michigan, 547 U.S. 586 (2006) (suppression is not always required remedy for Fourth Amendment violations)
Davis v. United States, 564 U.S. 229 (2011) (limitations on exclusionary-rule relief when law was unsettled)
Arizona v. Fulminante, 499 U.S. 279 (1991) (harmless-error analysis for constitutional errors)