Zanders v. StateAnnotate this Case
The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt.
Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt.