Jefferson v. State
The Sixth DCA held that the trial court erred in relying on the 'open view' doctrine from Purifoy to justify the warrantless seizure of a murder suspect's cell phone, because there was no evidence establishing the phone's location when seized. The court further held that the State's generalized suspicion that communications between the suspect and victim 'would likely' exist on the phone was speculative and insufficient to establish probable cause for a warrantless seizure, though the error was ultimately deemed harmless given overwhelming independent evidence.
Key facts
- Jefferson was charged with murder; a trial court admitted evidence obtained from a warrantless seizure of his cell phone at the time of his arrest.
- The police seized Jefferson's cell phone without a warrant based on generalized suspicion that communications between Jefferson and the victim would likely exist on the phone.
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Why it matters
This opinion gives criminal practitioners a clear articulation that probable cause—not mere speculation about what a phone 'might' contain—is required before police may seize a cell phone without a warrant, and it… — full analysis with a trial
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