Background
After an investigation into the defendant’s business activities, local officers obtained a warrant to search his residence for electronic devices and records related to crimes including operating without a license and violating a judicial order. During the search, officers found a thumb drive labeled boys in a safe, which contained child pornography. The defendant moved to suppress the evidence, arguing the warrant lacked particularity and was overbroad.
The court’s reasoning
The court concluded that the good faith exception applies because the warrant was not so facially deficient that no reasonable police officer could presume its validity. The court found that the warrant’s description of the search was sufficiently particular given the circumstances and that the broad scope of devices authorized was reasonable for the investigation. The court noted that the omission of a date range did not render the warrant invalid under the good faith exception.
What it means going forward
This ruling reinforces that evidence obtained under a warrant with potential deficiencies may still be admissible if the officers acted in objective good faith and the warrant was not so facially deficient that no officer could reasonably rely on it.