State v. Forte, ___ N.C. App. ___, 810 S.E.2d 339 (Jan. 16, 2018)

The trial court properly issued an order authorizing a pen register for the defendant’s phone. The order was issued pursuant to the Stored Communications Act (SCA). The SCA requires only reasonable suspicion for issuance of an order for disclosure. The order in question was based on information provided by a known drug dealer informant, Oliver. The court found that there were “multiple indications of reliability” of Oliver’s statements, including that he made substantial admissions against his penal interest. Also, Oliver provided a nickname, general description of the defendant, background information from dealing with him previously, and current travel information of the suspect. Oliver spoke with the officer, and the two spoke more than once, adding to the reliability of his tip. These facts met the standard under the SCA.