United States v. Bledsoe, 630 F.Supp.3d 1

Background

On Jan. 6, 2021, rioters stormed the U.S. Capitol; many filmed or live-streamed events from inside the building.
The FBI used the SCA emergency-disclosure provision to ask Facebook to identify accounts that streamed or uploaded videos from physically inside the Capitol during the riot; Facebook voluntarily disclosed Object IDs and User IDs on Jan. 6, Jan. 13, and Jan. 22, 2021.
Using those User IDs, the FBI obtained a magistrate-issued warrant (Mar. 3, 2021) for content and records from 25 Facebook/Instagram accounts (including defendant Matthew Bledsoe’s) dating back to Nov. 2020.
Bledsoe was identified from Facebook’s production, charged, tried, and convicted of multiple January 6–related offenses.
Bledsoe moved to suppress non-public account content and derivative evidence, arguing (1) Facebook’s initial voluntary disclosure was a Fourth Amendment search under Carpenter and (2) the search warrant lacked probable cause (and that the good-faith exception does not save it).
The court denied the suppression motion: it found no Fourth Amendment search in Facebook’s voluntary disclosure of user-identifying, user-generated location info (UGLI) and held the warrant was supported by probable cause (and alternatively not subject to suppression under the good-faith doctrine).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Facebook’s voluntary disclosure to the FBI identifying accounts that streamed/uploaded videos from inside the Capitol was a Fourth Amendment search	Gov’t: Third-party doctrine controls; users voluntarily conveyed account/activity data to Facebook; Carpenter is narrow and doesn’t reach UGLI derived from user-posted content	Bledsoe: Carpenter requires a warrant for location-linked records; UGLI reveals time/place of a user and thus is protected like CSLI	Court: Not a search. Bledsoe failed to show a reasonable expectation of privacy in the disclosed UGLI; Carpenter is distinguishable (UGLI is volitional, limited, and not a comprehensive long-term chronicle)
Whether the Social Media Warrant lacked probable cause to search non-public account content	Gov’t: Warrant affidavit gave a substantial basis—Facebook metadata/IP and corroboration connected accounts to in-Capitol activity during the riot; fair probability evidence would be found	Bledsoe: Affidavit only shows that accounts "may" have streamed from the Capitol—at best a possibility, not probable cause	Court: Probable cause existed; the magistrate had a substantial basis to conclude the accounts would contain evidence. Admission of the seized exhibits was proper
Whether evidence should be excluded under the exclusionary rule (good-faith / emergency disclosure issues)	Gov’t: Even if problems existed, good-faith reliance and SCA emergency procedures would preclude exclusion	Bledsoe: Facebook’s Jan. 22 disclosure and the government’s delay undermine any emergency justification; suppression appropriate if warrant deficient	Court: Did not rely on the emergency SCA justification (record sparse) but held exclusion unnecessary because no Fourth Amendment violation and, alternatively, the warrant/supporting affidavit was not so deficient as to bar good-faith reliance

Key Cases Cited

Carpenter v. United States, 138 S. Ct. 2206 (2018) (historical CSLI can be a Fourth Amendment search; warrant generally required)
Smith v. Maryland, 442 U.S. 735 (1979) (third-party doctrine: no reasonable expectation of privacy for information voluntarily conveyed to a third party)
United States v. Miller, 425 U.S. 435 (1976) (records held by a third party are not protected by the Fourth Amendment in the same way as private papers)
Katz v. United States, 389 U.S. 347 (1967) (reasonable-expectation-of-privacy test)
United States v. Jones, 565 U.S. 400 (2012) (long-term location tracking implicates heightened privacy concerns)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause for warrants assessed under totality-of-the-circumstances; fair probability standard)
United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to exclusionary rule)
Mapp v. Ohio, 367 U.S. 643 (1961) (exclusionary rule applies to Fourth Amendment violations)