People of the State of Michigan v. Kenneth McDonald

Summary

The Michigan Court of Appeals affirmed the trial court’s order suppressing evidence obtained from Kenneth McDonald’s cell phone. The court held that the search warrant lacked sufficient particularity and failed to establish an adequate nexus between the broad categories of digital data sought and suspected criminal conduct. The court also concluded that the good-faith exception to the exclusionary rule did not apply because the warrant was facially deficient.

Holdings

1. The warrant was constitutionally invalid because it authorized an essentially unrestricted search of McDonald's cell-phone data without identifying the offense under investigation, establishing a sufficient nexus between the data sought and suspected criminal conduct, or limiting the search by relevant data categories or time periods.
2. The good-faith exception to the exclusionary rule did not apply because the warrant was so facially deficient in particularity that executing officers could not reasonably have presumed it valid.
3. The Court declined to sever portions of the warrant because the prosecution failed to provide an adequately briefed severance analysis showing that valid categories were distinguishable from invalid categories and constituted the great part of the warrant.

Questions Presented

1. Whether the search warrant for McDonald's cell phone satisfied the Fourth Amendment and Michigan Constitution's particularity requirement.
2. Whether the good-faith exception to the exclusionary rule rendered the evidence admissible despite the warrant's constitutional deficiencies.
3. Whether portions of the warrant could be severed so that some cell-phone data could be admitted.

Disposition

affirmed