Carpenter v. United States

Facts of the case

Four men were arrested in April 2011 for a case of armed robbery. The F.B.I.
interrogated the four men involved in the crimes, and one of them confessed to the crimes and
gave out his phone number and the phone numbers of other suspects. The law enforcement used
this information to acquire phone records, “transactional records,” and the judges had granted
permission of the said records as per the provisions of the Stored Communications Act (Find
Law, 2018). The Act states that where there is reasonable suspicion that the content contained in
the person’s electronic communication is relevant to an ongoing criminal investigation, the
government might request disclosure of the said communication records.
In this case, the records accessed by the F.B.I. included time and date of calls, when the
calls were made and when they ended, and also the locations of the phone when the calls were
made. They used this information to charge Timothy Carpenter of aiding and abetting robbery.
The Petitioner, Carpenter, denied the charges on the basis that the evidence obtained from his
cell phone could not be used as evidence as it was obtained without a search warrant which is
contrary to the Fourth Amendment.

The Issue

The issue, in this case, was whether the search and taking of cell phone records that
include movement of the phone owner and his location amounted to a violation of his Fourth
Amendment rights.

The Law

The Fourth Amendment not only protects a person from “unreasonable searches and
seizures “of his property by the government but also from other forms of intrusion by the

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government (Legal Information Institute, 2020). A person is entitled to privacy, and tracking the
records of his movement and location amounts to intrusion, which is contrary to the provisions of
the Fourth Amendment

Legal Systems.

The government used the information obtained from the cell records to connect Carpenter
to the robbery. They tracked his location, and they later used this information to prove that he
was within a radius of 2 miles of the locations of the four crimes when they happened. He was
charged at found guilty of many counts of aiding and abetting robbery. The United States District
Court of Michigan sentenced him to 116.25 years or 1395 months in federal prison.
Carpenter appealed the decision of the District Court to sentence him to the Court of
Appeals for the Sixth Circuit. His case was heard by a panel of three judges in 2015 on October
14th. In 2016, the United States Court of Appeals stated its opinion that was delivered by Judge
Kethledge. He affirmed the Appellant’s sentence and conviction. The decision of the Sixth
Circuit was guided by the decision of the Supreme Court in Smith v. Maryland that stated that
the Fourth Amendment protected only the content of a person’s communication.
In September 2016, Carpenter sought a judicial review by the United States Supreme
Court. The Court agreed to review his case, and twenty briefs were filed by friends of the Court
and organizations. On June 22 nd, 2018, the Court issued its opinion in a majority of 5-4. The
Court utilized two cases in deciding Carpenter’s case, United States v. Jones and Smith v.
Maryland. The majority held that the government must have a warrant in order to access the
CSLI records. The dissents justices each filed their opinion. Justice Kennedy was of the opinion
that cell-site records are similar to business records, and the government has the right to obtain
them without needing permission to do so. Justice Thomas filed his dissent opinion that the

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question in Carpenter’s case should not dwell on whether there was a search but should look at
the person whose property was searched. Justice Gorsuch’s dissent opinion was that the Court
was moving away from the original provisions and meaning of the Fourth Amendment.This case
had a huge impact in setting precedent for deciding cases in modern societies with the new
technological developments that have ushered in the digital era.

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References

Carpenter v. United States. (2018). Oyez. Retrieved December 4th, 2021, from
https://www.oyez.org/cases/2017/16-402

Find Law. (2018, January 1st). 18 U.S.C. § 2703 – U.S. code title 18. Crimes and criminal
procedure § 2703 | FindLaw. Findlaw. https://codes.findlaw.com/us/title-18-crimes-and-
criminal-procedure/18-usc-sect-2703.html
Legal Information Institute. (2020). Fourth Amendment. LII / Legal Information Institute.
https://www.law.cornell.edu/constitution/fourth_amendment