Background
Rayevon Deschambault was arrested for drug trafficking after a controlled purchase of cocaine base. Police searched his cell phone pursuant to a state warrant and found videos depicting sexual acts with a minor. Deschambault was charged with sexual exploitation of a minor under 18 United States Code Section 2251(a). He moved to suppress the videos, arguing the warrant lacked probable cause and particularity, and that officers exceeded the warrant’s scope. He also challenged the voir dire questions regarding racial bias and the exclusion of evidence regarding his belief about the victim’s age.
The court’s reasoning
The court found the state warrant supported probable cause and was sufficiently particular because it limited the search to data pertaining to drug trafficking and the phone’s ownership. The court held that officers did not exceed the warrant’s scope when they investigated the videos, as they were relevant to the drug investigation by linking the defendant to the location where drugs were found. The court affirmed the district court’s refusal to ask specific voir dire questions about interracial relationships, noting the questions asked were sufficient to probe racial bias. Finally, the court ruled that mistake of age is not a defense under 18 United States Code Section 2251(a) and that the jury instructions on the purpose element were correct.
What it means going forward
The decision reinforces that search warrants for cell phones in drug trafficking cases may authorize broad searches of digital content, including photos and videos, if tied to the crime. It also clarifies that the discovery of unrelated criminal evidence during a lawful search does not require a new warrant if the evidence is relevant to the original investigation.