CO: Quantity of documents sought in SW doesn’t make it overbroad

This documents warrant was particular. While it sought a lot of information, that alone didn’t make it overbroad. It was also limited in time to six months of information. People v. Rodriguez-Ortiz, 2025 COA 30 (Mar. 20, 2025):

[*P30] Second, while we agree that the warrant was, as in Roccaforte, broad, we conclude that this such fact is not dispositive. See People v. Tucci, 179 Colo. 373, 500 P.2d 815, 816 (Colo. 1972) (“[T]he quantity of items listed in a search warrant or the quantity of items seized during the execution of a warrant does not necessarily have any bearing on the validity of the search itself.”). Because the crimes occurred over six months and concerned a domestic violence relationship, conduct and communications surrounding the crimes were relevant to identifying Rodriguez-Ortiz as the suspect. Moreover, while the warrant allowed a search for text messages, call records, and data, unlike the warrant in Coke, it excluded much of the data contained in a cell phone, such as images, videos, and contact lists.

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