United States v. Mark Eggerson

Summary

The United States Court of Appeals for the Eighth Circuit affirmed Mark Eggerson’s conviction for being a felon in possession of a firearm. The court held that search warrants authorizing the seizure and search of his cell phone were supported by probable cause, were not facially deficient, and were relied upon in objective good faith. The court therefore upheld the denial of Eggerson’s motion to suppress evidence, including video found on the phone.

Holdings

1. The first warrant was not so facially deficient that an objectively reasonable officer could not rely on it. The warrant's authorization to search for items tending to show firearm possession, computers, cellular telephones, and electronic communications, together with the investigator's testimony that Eggerson had recently brandished a firearm, permitted reasonable reliance on the warrant to search the phone for evidence of illegal firearm possession.
2. The warrants were not impermissibly general in a manner that defeated the good-faith exception. A reasonable officer could read the first warrant as limiting the search and seizure of cell phones to devices tied to Eggerson and the drug- and firearm-related crimes under investigation, and the second warrant was even less suspect because it was limited to the contents of the already-seized phone.
3. There was a substantial basis for the state magistrate's probable-cause determination that the cell phone would contain evidence of drug trafficking and firearm possession. Even if probable cause were lacking, the good-faith exception would independently prevent suppression.
4. Riley v. California did not require suppression because the officers obtained warrants before searching the phone and its contents, and the warrants were supported by probable cause, were not facially deficient, and were relied on in objective good faith.

Questions Presented

1. Whether the first state search warrant was so general, overbroad, or unsupported by probable cause that no objectively reasonable officer could rely on it in good faith.
2. Whether the second state search warrant authorizing a search of the seized cell phone and its contents was valid or, alternatively, covered by the good-faith exception.
3. Whether the warrants violated the Fourth Amendment and the warrant requirement recognized in Riley v. California.

Disposition

affirmed