W.D.Wash.: iCloud SW temporal limit was impractical

An iCloud search warrant was not overbroad because the warrant sought a lot of material. Based on Apple’s protocols, it essentially had to be, and a time restriction wouldn’t be of any use. United States v. Woolard, 2021 U.S. Dist. LEXIS 33854 (W.D. Wash. Feb. 23, 2021):

Mr. Woolard does not contest that the Government had probable cause for seizure. With respect to the second Shi factor, the Court finds that this warrant had objective standards to guide the search of Woolard’s iCloud account, which were set forth in Part II of Attachment B. The Court finds that, like in Sam, supra, the warrant issued here was not required to include a temporal restriction on the seizure of the account because the entire account needed to be searched to find “records pertaining to the alleged crimes that occurred between January 1, 2013, and the present” and to link the account to Mr. Woolard. The nature of the way the information was stored made it impractical for Apple to apply temporal or content restrictions. The Court agrees with Sam as to there not being a constitutional requirement for the Government to use a filter team in this case. See 2020 WL 2131285 at *3. Given all of the above, the Court finds that Mr. Woolard has not set forth a basis to suppress this evidence.