United States v. Eric Curtis, 901 F.3d 846

Eric Curtis led a crew that robbed five suburban Chicago cell-phone stores; he was arrested after the last robbery and tried on ten counts (robbery, aiding brandishing, conspiracy, and felon-in-possession). The jury convicted him on all but two counts (both relating to the Joliet robbery).
The government obtained 314 days of Curtis’s historical cell-site location information (CSLI) via court orders under the Stored Communications Act (SCA); the CSLI placed him near four of the five robbed stores (no CSLI for Joliet).
Curtis moved to suppress the CSLI, arguing SCA orders did not satisfy the Fourth Amendment; the district court denied the motion relying on third‑party/voluntary disclosure precedent.
After Carpenter v. United States, which held that long-term CSLI is protected by the Fourth Amendment and that SCA orders fall short of a warrant, Curtis argued suppression was required here.
The court concluded suppression was not required because the officers and prosecutors relied in good faith on the SCA; applying the Krull good‑faith exception, exclusion was not warranted despite a constitutional error.
Curtis also sought to cross-examine government witnesses about possible bias arising from his cousin Ryan’s shooting by police and Curtis’s threatened complaint; the district court limited that line of inquiry and the Seventh Circuit held any Confrontation Clause error was harmless given the existing impeachment and strong CSLI/call-log evidence.

Issue	Curtis's Argument	Government's Argument	Held
Admissibility of historical CSLI obtained under SCA without a warrant	Carpenter requires suppression because long-term CSLI is protected by the Fourth Amendment and SCA orders are insufficient	Evidence need not be suppressed because law‑enforcement relied in good faith on the SCA; exclusionary rule unnecessary under Krull	Denied relief: good‑faith exception applies; CSLI admission stands
Right to cross-examine government witnesses about bias related to Ryan’s shooting and Curtis’s threatened complaint	Cross‑examination would show witnesses believed they would benefit by testifying against Curtis (bias/motive to lie)	Trial court properly limited speculative/prejudicial questioning; witnesses’ bias was already exposed	Any limiting error was harmless beyond a reasonable doubt given impeachment already elicited and strong CSLI/call‑log proof

Carpenter v. United States, 138 S. Ct. 2206 (2018) (long‑term CSLI implicates a legitimate expectation of privacy; SCA orders are not equivalent to warrants)
Illinois v. Krull, 480 U.S. 340 (1987) (good‑faith exception applies when officers rely on a statute later declared unconstitutional)
Delaware v. Van Arsdall, 475 U.S. 673 (1986) (Confrontation Clause error requires reversal unless harmless beyond a reasonable doubt)
Smith v. Maryland, 442 U.S. 735 (1979) (third‑party doctrine/voluntary disclosure principle)
United States v. Miller, 425 U.S. 435 (1976) (third‑party disclosure doctrine for business records)
United States v. Pembrook, 876 F.3d 812 (6th Cir. 2017) (applied Krull good‑faith rationale to CSLI obtained under the SCA)