Smith v. State

Summary

The court held that a warrant authorizing a search of Smith's apartment did not authorize officers to seize or search his cell phone while it was on his person outside the apartment, and an incorporated probable-cause declaration could not expand the warrant's scope. Exigent circumstances justified securing the phone to prevent destruction of evidence, but officers needed a separate warrant or independently applicable exigency to conduct the forensic search the next day. Because the phone evidence formed the bulk of the State's case, the court reversed the convictions and remanded.