State v. Smith

Summary

The court held that warrants authorizing searches of the defendant's cell phone and provider records were constitutionally defective because the affidavits failed to establish probable cause connecting the defendant, the devices, and the specified crimes. The cell-phone warrant also lacked particularity because it authorized an unrestricted extraction without limiting the data categories or time period, while the court could not determine whether the provider-record warrant satisfied particularity. The resulting error was harmless for some convictions but not for the convictions involving the second robbery, related vehicle theft, and arson, which were reversed and remanded for a new trial.