KS: Def voluntarily disclosed his cell phone passcode to the officers when the officer said he’d get a warrant

Defendant voluntarily disclosed his cell phone passcode to the officers when the officer said he’d get a warrant for it. State v. Harris, 2025 Kan. LEXIS 5 (Jan. 31, 2025):

Substantial competent evidence supports the district court’s finding, based on its assessment of the totality of the circumstances, that Harris’ disclosure of the cell phone passcodes was voluntary and not obtained in violation of his Fifth Amendment privilege against self-incrimination. The initial Miranda warning and Harris’ waiver were still valid at the second interrogation, so a renewed Miranda warning was not needed. Further, Detective Melvin had a reasonable basis to believe a court would issue an order to compel fingerprint access or the passcodes to the phones at the time the detective informed Harris that he could obtain such an order, so this tactic was not inherently coercive. Finally, considering the totality of the circumstances, including the details of the second interrogation and Harris’ specific characteristics, we conclude Harris provided the passcodes voluntarily of his own free will. Thus, the district court did not err by denying Harris’ motion to suppress the evidence retrieved from the cell phones as a result of his voluntary disclosure of the passcodes.