DE: Def’s consent overcame overbreadth issue; “all digital contents” includes photos

The scope of the search of defendant’s cell phone data was overbroad, but defendant consented: “However, Defendant consented to the search of ‘all digital contents’ of his cell phone. Based on the scope of this consent, the police were permitted to obtain the photograph.” State v. Blackwood, 2020 Del. Super. LEXIS 105 (Feb. 27, 2020).*

The state showed that the facts developed before defendant’s arrest supported it, not what they learned after. State v. Jordan, 2020-Ohio-689, 2020 Ohio App. LEXIS 650 (1st Dist. Feb. 28, 2020).*