Case Brief for Carpenter Vs. the United States
Carpenter v. the United States (2018)
This case in 2018 pitted Timothy Ivory Carpenter against the United States of America.
Procedural Posture
Carpenter moved to the District Court to stop the State from using the cell-site data provided by wireless carriers. After the District Court denied his motion, he moved to the Court of Appeal, which affirmed the decision. Finally, the Supreme Court reversed the earlier decision, arguing that the government has no right to obtain private records from third parties for use in a case against the individuals. Consequently, the decision made the lower courts based on Carpenter’s location data was quashed, and a new conclusion arrived at following his accomplices’ evidence.
Issue
May the State seize private communication data from individuals’ telecommunication records, considering that such compulsion may constitute an infringement on the individual’s right to privacy as contained in the Fourth Amendment?
Recitation of the facts
In 1994, Congress amended the Stored Communication Act to allow the government to compel telecommunication firms to disclose certain telecommunications records when it “offers specific and articulable facts showing that there are reasonable grounds to believe” that the records sought “are relevant and material to an ongoing criminal investigation” (“Carpenter V. United States, 585 U.S. ___ 2018”). Ivory Carpenter (complainant) sued the government (defendant)for acquiring private call and location information by compelling two firms, MetroPCS and Sprint, to release the records for investigation in a case in which he and three others faced charges of conducting a string of robberies in Michigan and Ohio. He failed in the Court of Appeal as federal magistrate judges directed the companies to provide the required records. However, the Supreme Court granted his wish.
Rule of Law
Without a warrant supported by the doctrine of probable cause, the State may not compel the release of privately held information, whether the individual lacks a reasonable expectation of privacy, to use such information to constitute evidence against the individual.
Holding and reasoning
No. the State cannot compel communication companies to reveal data about a client. The seizure of communication records from the two companies amounted to a search. Therefore, since it was not carried out without a search warrant supported by probable cause, the government erred. Although the government did not send personnel to trespass on a physical location, Carpenter’s call data acquisition without his express permission violated the terms of the Fourth Amendment. Even though the material may contain incriminating evidence, there exist other legal means of proving the case.
Moreover, although Carpenter voluntarily shared his location information with the wireless carriers, thereby rendering his reasonable expectation of privacy null, it was not within the Court’s jurisdiction to exploit that gap. In this case, the evidence provided without using the controversial records was enough to incriminate Carpenter. In conclusion, the Supreme Court reversed the Court of Appeal’s decision that justified the intrusion.
Judgment
The Court found Carpenter guilty of five of the six gun counts he was charged with and sentenced him to 1, 395 months in prison. Due to evidence by his accomplices, which placed him at the center of the robberies, Carpenter was convicted of the offences based on witness accounts. The Court argued that an individual maintains a legitimate expectation of privacy in the record of his physical movements as captured through CSLI. That location information obtained from Carpenter’s wireless carriers were the result of a search (“Carpenter V. United States, 585 U.S. ___ 2018”). Thus, he was convicted on other evidence.
Work Cited
“Carpenter V. United States, 585 U.S. ___ (2018)”. Justia Law, 2020, https://supreme.justia.com/cases/federal/us/585/16-402/#tab-opinion-3919270. Accessed 26 May 2020.