Chatrie v. United States · ¶78

At step two, the warrant authorized officers to access an additional hour’s worth of Location History, unbounded by the geofence’s perimeter. Though the warrant stated that officers would “attempt to narrow down the list” of devices subject to this step, there was no explicit requirement that they do so. 2 App. 136 (emphasis added). Nor did the warrant set forth any criteria that officers would use in their narrowing efforts. Ibid.

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