People of Michigan v. Michael Georgie Carson

Summary

The court held that the warrant authorizing the search of Carson’s cell phone violated the Fourth Amendment’s particularity requirement because it permitted an essentially unrestricted search of the phone’s data. Nevertheless, the court held that Carson failed to prove ineffective assistance of counsel because counsel’s decision not to challenge the warrant’s particularity was objectively reasonable under the legal landscape existing when counsel acted. The court reversed the relevant portion of the Court of Appeals judgment and remanded for consideration of Carson’s remaining issues.