In Commonwealth v. Davis, the Pennsylvania Superior Court dealt with historical cell-site location information (CSLI) and Carpenter v. United States. Law enforcement initially obtained CSLI data with orders secured under the state and federal wiretap acts. Those orders were based on a quantum of evidence that was less than probable cause. But shortly after the information was received, the U.S. Supreme Court issued Carpenter. Thus, law enforcement secured a warrant and obtained the exact same information as before. The affidavit supporting the application for the warrant did not contain all of the evidence supplied to get the earlier orders. The Court ruled that the evidence was admissible under the inevitable discovery doctrine, and the warrant was supported by probable cause.
