AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant was a passenger in a vehicle owned and driven by an individual under investigation for trafficking methamphetamine and cocaine. During a search of the vehicle, authorized by a warrant, officers found multiple cell phones along with drugs, paraphernalia, guns, and money. One of the flip cell phones, found on the floorboard of the front passenger seat, belonged to the Defendant and contained text messages concerning drug trafficking. The Defendant filed a motion to suppress evidence obtained from her cell phone, arguing that the search violated her Fourth Amendment rights, as the officers did not have a valid warrant for her cell phone specifically (paras 2-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant: Argued that the search of her flip cell phone and the use of information obtained from it to seek a second warrant constituted an illegal search, as the first warrant did not apply to her or her property, and the second warrant was based on illegally-seized evidence (para 4).
• State: [Not applicable or not found]

Legal Issues

• Whether the Defendant had a legitimate expectation of privacy in her flip cell phone found in the vehicle, and if she abandoned it by leaving it in the vehicle without taking steps to protect or safeguard its contents (para 5).
• Whether there was probable cause to search the Defendant's flip cell phone under the first search warrant issued for the vehicle and its contents (para 8).

Disposition

• The Court of Appeals affirmed the district court’s denial of the Defendant's motion to suppress the evidence taken from the flip cell phone (para 19).

Reasons

• Per M. Monica Zamora, J. (James J. Wechsler, J., and J. Miles Hanisee, J., concurring):
  The Court held that the Defendant did not abandon her flip cell phone simply by leaving it in the vehicle without taking steps to protect or safeguard its contents. The Court found no evidence that the Defendant intended to abandon the cell phone (para 6).
  Despite the above, the Court concluded that the district court's denial of the motion to suppress could be upheld for any reason, as long as it was not unfair to the appellant. The Court found that there was already probable cause to search all cell phones found in the vehicle under the first search warrant (para 7).
  The Court disagreed with the Defendant's claim that the first search warrant did not cover her flip cell phone because she was not specifically named in the affidavit or warrant. The Court determined that the search warrant applied to the entire vehicle and its contents, including any and all cell phones found within, based on the affidavit's detailed description of the investigation and the use of cell phones in drug trafficking operations (paras 8-15).
  The Court also noted that a second search warrant was obtained to search the cell phones after the initial discovery, which, while not technically necessary, provided additional authority to conduct a search for information pertaining to the distribution of controlled substances (para 18).