Young v. State
The Fourth DCA held that police violated the Fourth Amendment when a detective searched Facebook records—already lawfully obtained pursuant to an unrelated theft/fraud warrant—for evidence of a homicide, without obtaining a second warrant covering that new crime. The court rejected application of the good-faith exception because the search was directed by the prosecutor (not a neutral magistrate) and was not objectively reasonable given the theft warrant's narrower scope, and found the error was not harmless, reversing the manslaughter and attempted manslaughter convictions for a new trial.
Key facts
- Detective searched Facebook records and subscriber information already lawfully obtained under an unrelated theft/fraud warrant to gather evidence of a homicide, without obtaining a separate warrant for the new crime.
- Defendant was charged with manslaughter and attempted manslaughter; trial court denied suppression motion and admitted the Facebook-derived evidence, leading to conviction.
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Why it matters
This is a significant and fairly novel Fourth Amendment ruling for Florida on the permissible scope of searching digital evidence already in police possession under an unrelated warrant. It gives defense counsel a… — full analysis with a trial
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