MA: Arguing a “reddish-brown substance” could be a bunch of things and not blood “amounts to the type of ‘hypercritical analysis’ that is improper when reviewing search warrant affidavits”

The search warrant for defendant’s place for evidence of a murder showed nexus and probable cause including his car (because of distance to the homicide) and laptop (communicating with the victim). It was reasonable for the magistrate to conclude that “a reddish-brown stain” in his room was blood. He argued it “‘could be attributed to a multitude of substances’ and that treating it as blood reflects ‘an obvious confirmation bias.’ We disagree. The defendant’s argument amounts to the type of ‘hypercritical analysis’ that is improper when reviewing search warrant affidavits (citation omitted). … Read as a whole and with reasonable inferences, the reddish-brown stain was not simply found in the bedroom of a random teenager, but in the bedroom of the last person to see the victim alive — someone who also (1) met with the victim outside that bedroom shortly before her abandoned car was discovered, and (2) made efforts to hide the victim’s visit. The inference that the stain was blood was both reasonable and possible. See Gentile, 437 Mass. at 577 (seizure of defendant’s clothing was supported by probable cause where, inter alia, police observed stain believed to be blood on his pants).” Commonwealth v. Fujita, 2026 Mass. LEXIS 3 (Jan. 8, 2026).

iPhone warrant wasn’t too overbroad. “The warrant at issue here did not authorize officers to engage in an exploratory rummaging; rather, they were only authorized to search for evidence related to the drug crimes set forth in the warrant and accompanying application. The warrant includes broad language but does not amount to a blank grant to search the contents of the phone for ‘all data’ contained within it as Gamon alleges.” United States v. Gamon, 2026 U.S. Dist. LEXIS 2409 (M.D. Pa. Jan. 7, 2026).*