United States v. Barnes, No. 20-2583 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress geolocation data from his cell phone and his Google email account. The court concluded that officers were entitled to rely on the magistrate's nexus finding, and thus the Leon good faith exception applies to the warrants. The court also rejected defendant's contention that his trial was spoiled by the cumulative effect of a few evidentiary rulings. The court explained that, even if all of this evidence was excluded, the core facts supporting the verdict remain.
Court Description: [Kobes, Author, with Colloton and Wollman, Circuit Judges] Criminal case - Criminal law. Defendant challenges denial of his motion to suppress GPS tracking data from his phone and Google email account; the officers were entitled to rely on the magistrate judge's finding that the there was nexus between the geolocation data requested by the warrant and criminal activity and the Leon good faith exception applied to the warrants; argument that the cumulative effect of alleged evidentiary errors denied defendant a fair trial rejected; even if all the objected-to evidence had been kept out, the core facts supporting the verdict remained.
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