E.D.Mich.: Broad SW for cell phone photos was reasonable because of how they’re stored

A broad search warrant for photographs on a cell phone was reasonable because that’s the only way the photos can be searched. In addition, the good faith exception applies. United States v. Hawkins, 2019 U.S. Dist. LEXIS 214030 (E.D. Mich. Dec. 12, 2019).*

Defendant’s conduct was sufficiently continuing that the search warrant for his house wasn’t stale for firearm parts shipped to him over a long period of time. It was ongoing, “entrenched,” and the things sought were likely to be kept. “The final factor the Court considers is whether the place identified by the search warrant is a ‘mere criminal forum of convenience or secure operational base.’ There is a greater probability of finding evidence at a location that is ‘at the heart of the criminal charges.’” Nexus was also clearly shown. Finally, the good faith exception applies. United States v. Bryant, 2019 U.S. Dist. LEXIS 214026 (E.D. Mich. Dec. 12, 2019).*

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