W.D.Mo.: SW for cell phone includes its SD card, just as a computer SW includes the hard drive

A search warrant for a cell phone includes the SD card in it, just the same as a computer search warrant authorizes the search of the hard drive: “Such reasoning is analogous to the instant matter. For one, a micro SD card and external hard drive are substantially similar and functionally the same. Both are storage devices that can be separated from other digital devices and transported. Both are solely used to store digital data. Both are ‘functionally inoperable—and their contents unreviewable—when unplugged from a’ digital device. Beckmann, 786 F.3d at 679. Accordingly, an external hard drive is nearly identical to a micro SD card. Moreover, in the Eighth Circuit a cell phone is equivalent to a computer under the sentencing guidelines. United States v. Kramer, 631 F.3d 900, 902-03 (8th Cir. 2011).” There was also probable cause for search of the phone. United States v. Wilson, 2019 U.S. Dist. LEXIS 166318 (W.D. Mo. Sept. 16, 2019).

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