State v. Correa

Summary

The court held that the warrant authorizing a search of all data on the defendant's cell phone violated the Fourth Amendment because it lacked content and temporal limits, even though the warrant incorporated an affidavit identifying the relevant offenses. The trial court could not cure that defect by severing or adding a temporal limitation, but the erroneous admission of the phone evidence was harmless beyond a reasonable doubt because the remaining evidence was strong, independently corroborative, and the phone evidence was largely cumulative. The judgment of conviction was therefore affirmed.