United States v. William Wallace, 885 F.3d 806

William Chance Wallace, an armed career criminal and confirmed gang member, was located in May 2015 after DPS obtained real-time E911 (cell‑site/GPS) data via state “Ping Orders” and AT&T; officers arrested him and seized a pistol and ammunition.
DPS obtained two court orders (Ping Orders) after a confidential informant gave Wallace’s number; Wallace’s phone initially was off, then a second number produced a real‑time location.
Wallace was charged with being a felon in possession of a firearm; later he pled guilty to aiding and abetting retaliation against a witness and waived most appellate rights.
Wallace moved to suppress the gun, ammo, and related testimony, arguing the Ping Order was invalid because the statutes require a showing that the information sought be relevant to an “ongoing criminal investigation” and that officers needed a probable‑cause warrant for E911 data.
The district court denied suppression; Wallace appealed only the suppression ruling preserved in his plea agreement. The sentences were consolidated and the district court reserved reconsideration of sentence if the firearms conviction were overturned.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Ping Order satisfied the statutory requirement that the information be relevant to an “ongoing criminal investigation”	Wallace: “ongoing criminal investigation” requires new criminal activity and does not cover probation violation or stale matters; Ping Order therefore invalid	Government: orders were sought pursuant to federal pen‑trap/SCA and Texas statute for an ongoing investigation into Wallace (including fugitive/probation violation); orders were judicially authorized	Court: Did not reach definitional limits because suppression is not a statutory remedy for violations of the pen‑trap statute, SCA, or Texas Art. 18.21; denial affirmed
Whether obtaining E911 real‑time location data violated the Fourth Amendment and required suppression	Wallace: access to E911 data was a warrantless search; suppression required because order lacked probable‑cause warrant support	Government: officers obtained a court order under statutory authority, acted in good‑faith reliance on statute and court order; exclusionary rule inapplicable	Court: Even assuming a search, officers acted in objectively reasonable reliance on statute/court order; good‑faith exception applies; denial affirmed

United States v. Turner, 839 F.3d 429 (5th Cir.) (standard of review for suppression rulings)
United States v. Hearn, 563 F.3d 95 (5th Cir.) (review standards for suppression)
United States v. Waldrop, 404 F.3d 365 (5th Cir.) (affirming on any record‑supported rationale)
United States v. German, 486 F.3d 849 (5th Cir.) (suppression is not a remedy for pen‑trap statute violations)
United States v. Guerrero, 768 F.3d 351 (5th Cir.) (suppression not available for SCA violations)
United States v. Calandra, 414 U.S. 338 (U.S.) (exclusionary rule and fruits doctrine)
Kyllo v. United States, 533 U.S. 27 (U.S.) (when government conduct constitutes a Fourth Amendment search)
Katz v. United States, 389 U.S. 347 (U.S.) (reasonable expectation of privacy test)
United States v. Leon, 468 U.S. 897 (U.S.) (good‑faith exception to exclusionary rule)
Illinois v. Krull, 480 U.S. 340 (U.S.) (officers reasonably relying on statute may be protected from exclusionary remedy)
United States v. Watson, 423 U.S. 411 (U.S.) (presumption of constitutionality of congressional acts)