United States v. Jay Goldstein, 914 F.3d 200

Jay Goldstein was arrested in a kidnapping investigation; prosecutors obtained 57 days of his cell-site location information (CSLI) under 18 U.S.C. § 2703(d) (SCA) via a court order.
CSLI records identify which cell tower a phone connected to over time, revealing movements.
§ 2703(d) requires a showing of “specific and articulable facts” of relevance, not probable cause.
Goldstein moved to suppress the CSLI as a Fourth Amendment search requiring a warrant; the District Court denied suppression and his conviction followed.
The Third Circuit previously held in Stimler and In re Application that users had no reasonable expectation of privacy in CSLI and that § 2703(d) was constitutional.
After the Supreme Court decided Carpenter (recognizing a privacy interest in CSLI and requiring probable-cause warrants), the Third Circuit concluded the § 2703(d) acquisition here was a Fourth Amendment search but affirmed admission under the good-faith exception to the exclusionary rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether acquisition of CSLI under § 2703(d) violated the Fourth Amendment	Goldstein: CSLI is protected; § 2703(d) lacks probable cause and thus unconstitutional	Government: § 2703(d) was permissible because prior Third Circuit precedent permitted CSLI collection without probable cause	Applying Carpenter, the court held obtaining CSLI under § 2703(d) was a Fourth Amendment search that requires a probable-cause warrant
Whether the exclusionary rule bars admission of CSLI obtained under § 2703(d) before Carpenter	Goldstein: Evidence should be suppressed despite Carpenter because reliance on § 2703(d) was unreasonable or not within good faith	Government: Officers and prosecutors reasonably relied on a then-valid statute, a valid judicial order, and binding Third Circuit precedent (In re Application)	The good-faith exception applies; evidence need not be suppressed because reliance on the statute, order, and binding precedent was objectively reasonable

Carpenter v. United States, 138 S. Ct. 2206 (recognizing a legitimate privacy interest in CSLI and requiring probable-cause warrants)
United States v. Stimler, 864 F.3d 253 (3d Cir. 2017) (prior Third Circuit panel decision finding no expectation of privacy in CSLI)
In re Application of the United States, 620 F.3d 304 (3d Cir. 2010) (held CSLI obtainable under § 2703(d) without traditional probable cause)
Illinois v. Krull, 480 U.S. 340 (1987) (good-faith exception applies when officers reasonably rely on a statute later held unconstitutional)
Davis v. United States, 564 U.S. 229 (2011) (good-faith reliance on then-binding appellate precedent bars exclusion)
United States v. Leon, 468 U.S. 897 (1984) (exclusionary rule does not apply when officers reasonably rely on a judicially issued warrant later found invalid)
United States v. Jones, 565 U.S. 400 (2012) (GPS long-term tracking decision; distinguished from CSLI)
Riley v. California, 134 S. Ct. 2473 (2014) (search of cell-phone contents; distinguished from metadata/CSLI)