“Here, the seizure of Fulton’s cell phone during his arrest fell squarely within the exception articulated in Chimel and Robinson as a seizure incident to arrest.” United States v. Fulton, 2016 U.S. Dist. LEXIS 83014 (S.D.Tex. June 23, 2016).
The following was not an overbroad description in a search warrant: “Drugs of abuse, * * * Drug Paraphernalia, * * * and other items which are evidence of and in violation of ORC 2925.03 Trafficking in Drugs. These items include but are not limited to scales, packaging materials, paraphernalia, weapons, pagers, scanners, notes, records, mail, ledgers, photographs, receipts, address books, phone books, cell phones, any and all electronic communication devices, caller ID boxes, answering machines, financial records, conveyances, books, safes, safety deposit box keys, U.S. currency, checks, money drafts, real estate drafts, deposit slips, canceled checks, any funds gained from sales, printouts, computers, media storage devices and evidence of expenditure(s) of currency and currency equivalents, and items bartered or sold in exchange for said contraband, and any vehicles used in the transportation of said contraband.” State v. Bangera, 2016-Ohio-4596, 2016 Ohio App. LEXIS 2436 (11th Dist. June 27, 2016).*