DE: SW also for documents permitted seizure of a cell phone because nexus was shown; second warrant for contents of phone

Police were justified in entering defendant’s apartment without a warrant under the clothing exigency to retrieve clothing reasonably calculated to lessen the risk of injury to defendant, who was wearing only a t-shirt, underwear, and no shoes to go to jail in mid-November. Because the search warrant described documentation, police were permitted to seize defendant’s cell phone and get a second warrant to look at it. Even if the phone was outside of the scope of the first warrant, the police were still allowed to seize the phone because it was in plain view and there was a nexus between the phone and the crime given its location and the documents attached to the phone. State v. Palmer, 2016 Del. Super. LEXIS 204 (May 16, 2016).