Andrews v. Baltimore City Police Department, No. 18-1953 (4th Cir. 2020)
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Plaintiff alleged that the Baltimore Police Department conducted a warrantless search when it used a cell site simulator to locate him. In 2014, the police department used a Hailstorm cell site simulator to locate plaintiff's cell phone and thus defendant.
Absent a more detailed understanding of the Hailstorm simulator's configuration and surveillance capabilities, the Fourth Circuit could not address the issues necessary for resolution of this case. Therefore, the court remanded for further factfinding into the characteristics of the Hailstorm cell site simulator.
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