Mississippi Federal Judge Rules Tower Dump Warrants Per Se Unconstitutional
A federal judge in the Southern District of Mississippi ruled Wednesday that tower dump warrants are per se unconstitutional under the Fourth Amendment, denying the government’s request to reverse a magistrate judge’s decision refusing four such applications. The order, entered by U.S. District Judge Carlton W. Reeves in In re Four Applications for Search Warrants Seeking Information Associated with Particular Cellular Towers, No. 3:25-CR-38, states that neither the Supreme Court nor the Fifth Circuit has yet opined on the constitutionality of the technique.
A tower dump compels a wireless carrier to disclose time-and-location data for every cellular device that connected to a specified tower during a specified window. Federal agents sought the four warrants at issue as part of an ongoing investigation into a series of violent crimes in the Jackson metropolitan area that the government attributes to a gang and its rivals over a 14-month period, according to the court’s order. Some suspects have been identified; others have not.
The magistrate judge denied the applications. The government moved for review before the district court, arguing the warrants were supported by probable cause and appropriately limited in scope. The underlying docket materials, including the warrant applications and the government’s supporting memorandum, remain sealed because of the ongoing investigation, the order notes.
What Judge Reeves Held
Judge Reeves wrote that tower dumps expose “the cellular records of countless individuals, the vast majority of whom were merely passing by a location at the ‘wrong’ time,” and concluded that such a search is unreasonable within the meaning of the Fourth Amendment. The court framed the constitutional problem as one of scope: the technique captures data on every device in range of a tower during the target window, sweeping in bystanders whose only connection to the investigation is physical proximity.
The order situates that conclusion within the Supreme Court’s location-data jurisprudence, including Carpenter v. United States, which held in 2018 that the government generally needs a warrant to obtain historical cell-site location information for a specific user. Judge Reeves treated tower dumps as raising a distinct and, in his view, more acute concern because the technique sweeps in a population of unidentified third parties rather than targeting an individual suspect.
The Chatrie and Smith Backdrop
The ruling arrives against an unsettled appellate landscape on adjacent surveillance techniques. In June 2026, the Supreme Court decided Chatrie v. United States, on review from the Fourth Circuit. The Chatrie opinion concerned a geofence warrant seeking Google Location History data within a 150-meter radius of a Virginia credit union robbery, using a three-step anonymization-and-narrowing protocol.
Before Chatrie reached the Supreme Court, the Fifth Circuit had held in United States v. Smith, 23-60321, that geofence warrants, “at least as described herein,” are unconstitutional under the Fourth Amendment, splitting with the Fourth Circuit. The Fifth Circuit nonetheless affirmed the denial of suppression there on good-faith grounds. The Southern District of Mississippi sits within the Fifth Circuit.
Four Tower Dump Warrants, All Refused
The order denies the government’s motion for review of the magistrate’s decision and refuses to authorize the four tower-dump warrants. Because the ruling turns on a categorical constitutional holding rather than deficiencies specific to these applications, its stated reach extends beyond the four warrants at issue.
The underlying criminal investigation continues. The order acknowledges that the government has identified some suspects and is seeking the tower dumps to identify others potentially involved in the violent crimes under investigation. The court did not address whether alternative investigative tools, including targeted warrants for named suspects’ cell-site records under Carpenter, remain available to the government in the same matter.
The order does not indicate whether the government will seek appellate review. The warrant applications and supporting documents remain under seal.
