CA6: PC for a cell phone SW shown because it was used in a fraud case; computer search standards applied and satisfied

In a fraud case, probable cause was shown to search a cell phone for both evidence of the fraud and text messages where the co-conspirators were communicating with each other. Nexus was shown because defendant was using his cell phone just before he was arrested. As with computers, there was no way in advance of the search the officers could know the forms of the information. “At the time of the seizure, however, the officers could not have known where this information was located in the phone or in what format. Thus, the broad scope of the warrant was reasonable under the circumstances at that time. See id. at 541 (quoting United states v. Meek, 366 F.3d 705, 716 (9th Cir. 2004) (‘The proper metric of sufficient specificity is whether it was reasonable to provide a more specific description of the items at that juncture of the investigation.’)).” United States v. Bass, 2015 U.S. App. LEXIS 6383 (6th Cir. April 15, 2015) (later ordered published).