Nelson v. State

Summary

The court affirmed the denial of Nelson’s motion to suppress electronic data extracted under 2020 search warrants. Although the delay between seizure of the devices and issuance of the 2020 warrants was unusually long, Nelson’s incarceration and failure to request return of the devices substantially reduced his possessory interest, and the State had a legitimate evidentiary interest in retaining them. The court therefore concluded that the delay did not violate the Fourth Amendment and declined to decide when a warrant is executed or other issues not necessary to the decision.