The Court held that the officer violated the defendant's Fourth Amendment right by opening his phone after the defendant's arrest, where the officer saw a picture of a firearm, but affirmed the district court's denial of the motion to suppress under the independent source doctrine, since the officers had already seen the picture on another occasion, and since there was probable cause notwithstanding the tainted picture.
The Court affirmed the district court's denial of the defendant's motion to suppress based on a federal search warrant that was based on a defective state warrant. Though the Court agreed with the defendant that “any probable cause deficiency with the state search warrant would, as a matter of law and logic on these facts, heavily inform any conclusion we reach about the sufficiency of probable cause in the federal warrant application,” the Court upheld denial of the motion to suppress since the federal agents acted in good faith when they relied on the state warrant. The Court held that the focus should have been on the federal agents, who had no reason to question the integrity of the state proceedings, though the Court acknowledged that the result may have been different if the record reflected that the FBI had more knowledge about the state court proceedings
The Court held that a warrant obtained after an illegal entry was an independent legal source for the drug evidence where the warrant application was supported by probable cause without the tainted information, and the Government’s decision to seek the warrant was not motivated by the illegal entry, despite inconsistent testimony from the agent at the suppression hearing and the agents’ decision to confirm the presence of methamphetamine before seeking a warrant.
The Court agreed that the initial warrant by local law enforcement failed to particularize that computers, electronics, or phones were to be seized, so the seizure of the phone was improper. However, the Court held that the evidence was admissible under the good faith exception, since the federal agents that later acquired the phone from the local police and executed a search warrant did not know the police seized it unlawfully (as they had held on to the phone for a year) and since the applicability of the warrant to cell phones was a close question.
The Court held that a knock-and-talk violation does not mandate suppression when a valid search warrant exists and the knock-and-announce violation has “nothing to do with the seizure of the evidence.” Here, the warrant was valid, and officers would have executed it and seized the evidence regardless of the alleged violation.
