E.D.Mich.: Cell phone SWs have to be considered like a computer search; this was broad yet still particular enough

The search warrant for defendant’s phone was broad, yes, but it was sufficiently particular, and the good faith exception applies as well. A cell phone is a computer, and the issue is analyzed the same. United States v. Chang, 2018 U.S. Dist. LEXIS 128223 (E.D. Mich. July 31, 2018):

True, this list encompassed a wide swath of records and information. But this was not unreasonable. The search of a cell phone, like a computer, “may be as extensive as reasonably required to locate the items described in the warrant based on probable cause.” See Richards, 659 F.3d at 538, quoting United States v. Burgess, 576 F.3d 1078, 1092 (10th Cir. 2009). And when the search is limited to a search for evidence explicitly authorized in the warrant, it is reasonable for officers to search various records and applications on the phone to determine whether they contain this evidence. See id. at 540. Because the warrant was so limited here, and did not permit a free-ranging search, it did not violate the particularity requirement.

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