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Warrants for Cell Phone Location

If police have a warrant to arrest someone, can they get a warrant for the cell phone provider to disclose the location of his cell phone?  Orin Kerr has this post at VC.  A federal magistrate judge said no, but Orin thinks the answer is yes.  He reasons by analogy to Steagald v. United States, 451 U.S. 204 (1981), regarding a search warrant to enter the home of a third person, where the person named in the warrant was believed to be.

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