State of Maine v. David W. Marble Jr., 218 A.3d 1157

On Dec. 25, 2015, two victims were found shot to death in a car after a 9‑1‑1 call; the male victim’s phone (used to call 9‑1‑1) was recovered at the scene.
Marble was a local drug dealer for whom the male victim worked; earlier that day the male victim and friends burglarized Marble’s apartment and stole guns, drugs, and other items.
Marble had recently acquired two handguns and had called the male victim multiple times in the two days before the killings, including one call ~80 minutes before the 9‑1‑1 call.
A detective obtained a warrant for historical cell site location information (CSLI) for seven numbers (including Marble’s) based on an affidavit recounting the above facts; police seized Marble’s CSLI under that warrant.
Marble moved to suppress the CSLI as obtained without probable cause; the suppression motion was denied, he was tried and convicted of two counts of intentional or knowing murder, and he appealed the denial of suppression.
The Maine Supreme Judicial Court affirmed, holding the affidavit gave a substantial basis to find probable cause that Marble was involved and that his CSLI would constitute evidence of the murders.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Marble)	Held
Whether the warrant affidavit established probable cause to seize Marble’s historical CSLI	Affidavit showed nexus: victim worked for Marble, repeated recent calls including one shortly before killings, recent burglary of Marble’s apartment, Marble obtained guns—supporting a fair probability CSLI would contain evidence	Affidavit did not provide probable cause to justify seizure of CSLI	Affirmed: magistrate had a substantial basis to find probable cause that Marble was involved and that his CSLI would contain evidence
Whether the trial court erred in instructing jury on accomplice liability	Evidence supported convictions under either principal or accomplice liability	Instruction was erroneous	Rejected: evidence sufficient to support accomplice or principal liability; instruction proper

Carpenter v. United States, 138 S. Ct. 2206 (CSLI acquisition is a Fourth Amendment search; privacy interest in historical CSLI)
Illinois v. Gates, 462 U.S. 213 (totality‑of‑the‑circumstances test for probable cause)
State v. Johndro, 82 A.3d 820 (warrant affidavit must show nexus between evidence and place to be searched)
State v. Nickerson, 574 A.2d 1355 (review standard: substantial basis for magistrate’s probable cause finding)
State v. Simmons, 143 A.3d 819 (probable cause requires a fair probability evidence will be found at location searched)
State v. Nunez, 153 A.3d 84 (evaluating affidavit facts in warrant applications for electronic‑device information)
State v. Samson, 916 A.2d 977 (appellate deference to magistrate’s probable cause finding)