Probable-Cause Warrant Needed for Cell-Tracking, Brooklyn Judge Rules
The decision may be the first time a state judge has ruled that a warrant based on probable cause, rather than on a lesser standard, is necessary before police deploy a cell site simulator.
November 15, 2017 at 10:41 AM
8 minute read
A state judge has thrown out the results of a lineup that identified a Brooklyn man charged with attempted murder because police used a cell site simulator to track him without securing a probable-cause warrant beforehand.
The decision, issued by Kings County Supreme Court Justice Martin Murphy, may be the first time a state judge has ruled that a warrant based on probable cause—rather than on a lesser standard such as reasonable suspicion—is necessary before deploying a cell site simulator, according to Barry Kamins, a former administrative judge for New York City's criminal courts and a former Supreme Court justice.
Addressing a motion to suppress filed by defendant Shuquan Gordon, Murphy drew a distinction between what information police may collect using a “pen register” or “trap and trace” warrant, and what they may discover using a harder-to-obtain “eavesdropping” warrant.
In People v. Gordon, 03414/16, the New York City Police had obtained in 2016, from then-Kings County Supreme Court Justice Alan Marrus, a pen register/trap and trace warrant that authorized officers to use a cell site simulator, Murphy wrote.
But he ruled that an eavesdropping warrant was needed before a cell site simulator's technology, which uses GPS tracking, could be deployed.
The judge pointed out that a pen register/trap and trace warrant may be issued based on only reasonable suspicion. An eavesdropping warrant requires probable cause.
But the New York City Police Department on Wednesday took issue with Murphy's decision, arguing that the judge was simply wrong on key factual points, including about whether a cell site simulator was used to locate the defendant in the case and potentially about the type of warrant issued in the investigation.
Lawrence Byrne, the police department's chief legal officer and a deputy commissioner, said in a telephone interview that “our records indicate that cell site simulator technology was not used in this investigation to arrest this individual.”
He also said that “any time we use our version of cell site simulator technology, we do it pursuant to a court order, based on probable cause.”
Byrne added that the New York City Police Department's particular cell site simulator technology “does not allow us to intercept the content of communications” of cell phone users, although it does perform GPS tracking.
Helen Peterson, a spokeswoman for the Brooklyn District Attorney's Office, said on Wednesday in an email, “We are evaluating the decision and considering our options.”
A cell site simulator, or colloquially a “Stingray,” emits a signal that compels area cellphones to connect to it rather than to a cell service tower, according to Murphy's description of the technology in his opinion. Ultimately, it reveals “highly precise real time cell phone location and the contents of voice and text communications,” Murphy wrote, and the device collects information directly from a target device, as opposed to from a third-party provider.
A pen register or trap and trace warrant is authorized under New York's CPL Art. 705.00, and that law makes it clear that it is improper to obtain information from a suspect's phone other than phone numbers dialed or otherwise transmitted in outgoing and incoming calls, or an originating phone number, Murphy wrote in his Nov. 3 opinion.
The cell site simulator collects far more data, using GPS, he said.
“It has been held that the use of a GPS or a location tracking device … elevates the level of intrusiveness,” Murphy wrote, adding, “With the requirement of probable cause, a warrant for GPS tracking devices fits into the statutory scheme for eavesdropping and visual surveillance warrants.”
“By its very nature … the use of a cell site simulator intrudes upon an individual's reasonable expectation of privacy, acting as an instrument of eavesdropping and requires a separate warrant supported by probable cause,” he also wrote.
Murphy suppressed the lineup results, but denied Gordon's motion regarding potential evidence derived from his behavior at the time of arrest. Gordon, who allegedly shot at another man from behind in early 2016, was also charged with first-degree assault, attempted first-degree assault, second-degree assault, and several firearm counts.
A state judge has thrown out the results of a lineup that identified a Brooklyn man charged with attempted murder because police used a cell site simulator to track him without securing a probable-cause warrant beforehand.
The decision, issued by Kings County Supreme Court Justice Martin Murphy, may be the first time a state judge has ruled that a warrant based on probable cause—rather than on a lesser standard such as reasonable suspicion—is necessary before deploying a cell site simulator, according to Barry Kamins, a former administrative judge for
Addressing a motion to suppress filed by defendant Shuquan Gordon, Murphy drew a distinction between what information police may collect using a “pen register” or “trap and trace” warrant, and what they may discover using a harder-to-obtain “eavesdropping” warrant.
In People v. Gordon, 03414/16, the
But he ruled that an eavesdropping warrant was needed before a cell site simulator's technology, which uses GPS tracking, could be deployed.
The judge pointed out that a pen register/trap and trace warrant may be issued based on only reasonable suspicion. An eavesdropping warrant requires probable cause.
But the
Lawrence Byrne, the police department's chief legal officer and a deputy commissioner, said in a telephone interview that “our records indicate that cell site simulator technology was not used in this investigation to arrest this individual.”
He also said that “any time we use our version of cell site simulator technology, we do it pursuant to a court order, based on probable cause.”
Byrne added that the
Helen Peterson, a spokeswoman for the Brooklyn District Attorney's Office, said on Wednesday in an email, “We are evaluating the decision and considering our options.”
A cell site simulator, or colloquially a “Stingray,” emits a signal that compels area cellphones to connect to it rather than to a cell service tower, according to Murphy's description of the technology in his opinion. Ultimately, it reveals “highly precise real time cell phone location and the contents of voice and text communications,” Murphy wrote, and the device collects information directly from a target device, as opposed to from a third-party provider.
A pen register or trap and trace warrant is authorized under
The cell site simulator collects far more data, using GPS, he said.
“It has been held that the use of a GPS or a location tracking device … elevates the level of intrusiveness,” Murphy wrote, adding, “With the requirement of probable cause, a warrant for GPS tracking devices fits into the statutory scheme for eavesdropping and visual surveillance warrants.”
“By its very nature … the use of a cell site simulator intrudes upon an individual's reasonable expectation of privacy, acting as an instrument of eavesdropping and requires a separate warrant supported by probable cause,” he also wrote.
Murphy suppressed the lineup results, but denied Gordon's motion regarding potential evidence derived from his behavior at the time of arrest. Gordon, who allegedly shot at another man from behind in early 2016, was also charged with first-degree assault, attempted first-degree assault, second-degree assault, and several firearm counts.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllEuropean, US Litigation Funding Experts Look for Commonalities at NYU Event
Trending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250