State v. Correa

Summary

The court held that the warrant authorizing a search of the defendant's phone for "all data" violated the Fourth Amendment's particularity requirement because it imposed neither meaningful content limits nor temporal limits. The trial court also improperly used severance to add a temporal restriction rather than salvage a valid portion of the warrant, but admission of the phone evidence was harmless beyond a reasonable doubt because the remaining evidence was strong, independently corroborative, and largely cumulative. The court assumed without deciding that the initial warrantless seizure of the phone was constitutional.