Shield Public Safety Training · Police Technology Case Law Center

State v. Martin

287 So. 3d 645 (Fla. 4th DCA 2019)

A Florida appellate decision on Stingray standing, undisclosed technology, warrant scope, good faith, and suppression.

CourtFlorida Fourth District Court of Appeal
DecisionNovember 27, 2019
Case NumberNo. 4D18-3417
OpinionPer curiam
TechnologyCell-site simulator and CSLI
TargetDanny Martin’s phone and location
Existing ProcessProvider-directed court orders
StandingEstablished for location-data search
Good FaithRejected
DispositionSuppression affirmed

Executive Summary

The Case in One Paragraph

Danny Martin’s mother was found dead in the apartment they shared. Investigators obtained court orders directing wireless providers to supply cellphone location information. The applications did not mention a cell-site simulator, and officers admitted that their practice at the time was not to disclose intended simulator use. Provider data brought police to a general area, and officers then used the simulator to find Martin sitting in the victim’s parked car with incriminating evidence. The trial court suppressed the evidence. The Florida Fourth District Court of Appeal affirmed. Martin challenged the seizure of his own location data, not merely a search of the victim’s vehicle, so he had a personal Fourth Amendment interest. The CSLI orders did not authorize simulator deployment, and good faith did not apply merely because no binding 2012 decision had yet squarely required a simulator warrant. Officers went beyond the authorized provider process and used a more invasive technique without disclosure.

Core RuleA person may challenge warrantless simulator collection of his location data even when police ultimately find him in someone else’s vehicle. A CSLI order that never mentions the simulator does not authorize it, and the absence of then-binding simulator precedent does not by itself establish good faith.

Key Holdings at a Glance

Location Data Was PersonalMartin challenged government tracking of his phone and location—not ownership of the victim’s car.
Standing Could Be Raised on AppealThe State could present the privacy-interest issue, but the existing record supported Martin.
CSLI and Simulator Use DifferProvider disclosure did not authorize direct police operation of a fake tower.
Disclosure Was MissingNeither the applications nor the orders mentioned a simulator.
No Good-Faith Safe HarborThe lack of binding adverse precedent did not make the undisclosed, out-of-scope search objectively reasonable.
Suppression AffirmedThe simulator-derived evidence remained excluded.

Investigation and Arrest

In 2012, Martin was charged with first-degree murder after his mother was found dead in their shared apartment. Detectives used cellular location methods to search for him. Provider-generated CSLI narrowed the search area but did not identify his exact position.

Officers then deployed a cell-site simulator. They found Martin sitting in the victim’s parked vehicle along with several items of evidence. He moved to suppress, contending that the tracking and resulting seizure violated the Fourth Amendment.

Why the Technology Mattered

CSLI is produced through a carrier’s network and typically reveals a phone’s general relationship to cell sites. A simulator instead impersonates a tower, causes nearby devices to respond directly to government equipment, and can identify a target phone’s precise location.

MethodCollectorTypical ResultAuthorization Concern
Provider CSLIWireless carrierHistorical or real-time network-based locationOrder or warrant directs carrier disclosure
Cell-site simulatorLaw enforcementDirect target identification and precise locationRequires express authorization for active government collection

The Court Orders and the Undisclosed Simulator

Detectives applied under Florida statutes for orders authorizing acquisition of CSLI from service providers. The papers did not identify a cell-site simulator. Officers later acknowledged that disclosing intended simulator use was not their practice at the time.

The State argued that references to real-time or live location and a mobile tracking device reasonably included the simulator. Applying State v. Sylvestre, the court rejected that position: the authorized provider process and the police-operated simulator were materially different searches.

Candor RuleFunctional disclosure is essential. An application should state that police will operate equipment that impersonates a tower and induces target and non-target phones to connect.

Martin’s Fourth Amendment Interest

The State argued that Martin lacked standing because he was found in the victim’s vehicle and could not claim a privacy interest in it. The court held that this framed the challenged search incorrectly.

Martin contested the search and seizure of his cellphone location data. That personal information was used to locate him, regardless of who owned the physical place where officers ultimately found him. The record established the necessary connection between Martin, the target phone, and the tracking.

Standing PrincipleDefine the government conduct and privacy interest precisely. A defendant challenging technological location tracking need not prove ownership of every later place or vehicle in which the tracking finds him.

Why the Simulator Exceeded the Orders

The orders permitted officers to obtain information from wireless carriers. They did not authorize the State to operate its own surveillance equipment and force phones to reveal their location directly.

Once provider data brought investigators to a broad area, the officers used an unauthorized method to obtain the precision they still lacked. That was not simply a technical means of executing the same authority; it was a distinct collection method with additional privacy consequences.

Good-Faith Exception Rejected

The State emphasized that in 2012 no binding appellate decision expressly held that police needed a warrant to use a simulator. The court found that insufficient. Good faith is not established merely because no case has yet forbidden a new technique.

Officers did not disclose the simulator, and the orders did not approve it. They moved outside the authorized process when provider information could not supply the desired precision. The resulting violation was the kind of conduct suppression could deter.

Operational RuleWhen legal authority is uncertain, candidly disclose the technology and seek express judicial approval. Silence plus novelty is not objectively reasonable reliance.

Changing Location-Privacy Precedent

At the time of the 2012 investigation, the Florida intermediate appellate decision in Tracey I did not require a warrant for CSLI. The Florida Supreme Court later reversed that rule in Tracey II, and the U.S. Supreme Court decided Carpenter in 2018.

But the simulator problem remained distinct. The old CSLI decision did not affirmatively authorize an undisclosed, direct government technology. Sylvestre later confirmed that probable cause and a warrant are required for simulator deployment.

Why Suppression Was Affirmed

The simulator supplied the precise location leading officers to Martin and the evidence in the parked car. Because the deployment exceeded the court orders and good faith did not apply, the trial court properly suppressed the resulting evidence.

The decision reinforces that a court should examine the actual causal role of each technology rather than treating every location source as interchangeable.

Martin and Sylvestre Compared

IssueState v. SylvestreState v. Martin
Initial authorityCSLI and trap-and-trace ordersProvider-directed CSLI orders
Simulator disclosedNoNo
Where target was locatedInside a specific residenceIn the victim’s parked vehicle
Distinctive issueDirect versus indirect surveillance and derivative residential warrantPersonal location-data interest and good faith
ResultSuppression affirmedSuppression affirmed

Current Significance

Martin is especially useful when an agency obtained some legal process but used technology not described in the application. It cautions against assuming that statutory labels or broad location language cover every investigative method.

Agencies must apply controlling federal and state authority, statutes, constitutional provisions, warrant rules, and current technical capabilities. The safest planned-use practice is a detailed probable-cause warrant expressly authorizing the simulator.

Agency Operations Checklist

  1. Identify the target phone and offense nexus.
  2. Distinguish provider CSLI, GPS, pen-register data, and simulator collection.
  3. Name the simulator expressly in the application and warrant.
  4. Explain active phone connections and non-target collection.
  5. Set geography, duration, precision, power, activation, and termination limits.
  6. Prohibit unauthorized content collection.
  7. Minimize, segregate, and delete non-target data.
  8. Preserve applications, orders, logs, settings, outputs, operator notes, and deletion records.

Litigation and Review Checklist

  • Identify the precise government act being challenged and the defendant’s personal connection to the target data.
  • Do not collapse a location-data search into ownership of the place where the defendant was found.
  • Compare every affidavit and order with the technology actually used.
  • Determine whether officers disclosed the simulator and its functions.
  • Map what each location source contributed to finding the target.
  • For good faith, identify affirmative authority on which officers relied—not merely the absence of a prohibitory case.
  • Trace physical evidence and statements to simulator-derived information.

Frequently Asked Questions

Why could Martin challenge the search?

He challenged government acquisition of his phone’s location data, not a privacy interest in the victim’s car.

Did police have court orders?

Yes, but the orders concerned carrier-provided CSLI and did not mention or authorize a simulator.

Why did good faith fail?

Officers used undisclosed technology outside the orders’ scope. The lack of a then-binding case expressly prohibiting simulator use did not establish objectively reasonable reliance.

Did the court require a simulator warrant?

Applying Sylvestre, it reiterated that the State must establish probable cause and obtain a warrant before using a cell-site simulator.

What happened to the evidence?

The appellate court affirmed the trial court’s suppression order.

Primary Authorities and Related Law

State v. Martin, 287 So. 3d 645 (Fla. 4th DCA 2019)
Per curiam opinion affirming suppression of evidence derived from unauthorized simulator use.
Read the complete opinion
State v. Sylvestre, 254 So. 3d 986 (Fla. 4th DCA 2018)
Controlling district authority distinguishing provider orders from simulator deployment.
Read State v. Sylvestre
Tracey v. State, 152 So. 3d 504 (Fla. 2014)
Florida Supreme Court decision requiring probable cause for real-time cellphone-location tracking.
Read Tracey v. State
Carpenter v. United States, 585 U.S. 296 (2018)
Supreme Court decision addressing historical CSLI and the warrant requirement.
Read Carpenter v. United States

Final Assessment

State v. Martin shows that privacy analysis follows the data the government searched, not simply the physical location where police ultimately made contact. It also rejects a dangerous novelty principle: officers cannot treat new surveillance technology as warrantless by default until a court expressly says otherwise.

Shield Practice RuleIdentify the target privacy interest accurately, disclose the simulator and its active collection method, obtain express probable-cause authority, and never treat vague CSLI language or the absence of adverse precedent as a substitute for judicial approval.

Shield Public Safety Training · Police Technology Case Law Center

This monograph is provided for training and general informational purposes. It is not legal advice and does not replace review of complete opinions, current statutes, court rules, controlling federal and state authority, provider requirements, agency policy, technical documentation, or consultation with prosecutors and agency counsel.

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