South Carolina v. Warner
Annotate this CaseJustin Jamal Warner was convicted by jury of murder, attempted armed robbery, and possession of a weapon during the commission of a violent crime. The court of appeals affirmed. The South Carolina Supreme Court granted Warner's petition for a writ of certiorari to address: (1) whether the trial court was correct to deny Warner's motion to suppress cell-site location information (CSLI) seized from his cell phone service provider; and (2) whether an out-of-court viewing by Warner's probation officer of a crime-scene video and the officer's identification of Warner as the man in the video required a hearing under Neil v. Biggers, 409 U.S. 188 (1972). The Supreme Court found the trial court correctly ruled the identification made from the video did not require a Biggers hearing. As to the CSLI, the Court held the warrant the trial court found invalid because the warrant sought information stored in another state was not - at least for that reason - invalid. The Supreme Court affirmed the court of appeals as to the Biggers issue and remanded to the trial court for further proceedings as to Warner's motion to suppress CSLI.
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