N.D.Fla.: Def consented to providing pass code to his phone when police seized his phone pending getting SW

“The defendant delivered a package to a post office for mailing. A postal inspector caused the package to be held overnight and then, with the defendant’s consent, opened it. Finding cash and pills that appeared to be illicit, the postal inspector seized the defendant’s cellular phone, asked for and received from the defendant the pass code for unlocking the phone, obtained a warrant 12 days later, and caused a forensic search to be made of the phone’s contents. [¶] Following an evidentiary hearing, this order holds that there was probable cause to seize the package, that the defendant voluntarily consented to the search of the package, that the defendant voluntarily provided the pass code, that holding the phone for 12 days before obtaining a search warrant was reasonable—though just barely—and that the search warrant was valid. This order sets out the court’s findings of fact and conclusions of law and denies the defendant’s motion to suppress.” United States v. Hill, 2018 U.S. Dist. LEXIS 113124 (N.D. Fla. July 9, 2018).

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