State v. Wilson

After Bradly Jordan was shot and killed while doing pest control work, police tracked down Roceam Wilson's van and arrested him. During a search of the van, officers found two cell phones and later got a second warrant to search the phones for digital evidence. That warrant let police look for 'any and all stored electronic information' on the phones, including photos, texts, emails, and more. Wilson asked the trial court to throw out the phone evidence, arguing the warrant was so broad it amounted to a general search, which the Fourth Amendment forbids. The Gwinnett County trial court agreed and suppressed the evidence. The State appealed, arguing the warrant's language limited the search to crime-related evidence. The Supreme Court of Georgia disagreed and upheld the suppression, finding the warrant's boilerplate language did not actually narrow what police could seize.

A cell phone search warrant that authorizes seizure of 'any and all stored electronic information' without genuinely limiting the search to evidence connected to a specific crime fails the Fourth Amendment's particularity requirement and constitutes an unconstitutional general search, so the evidence was properly suppressed.

The decision limits how broadly Georgia police can word cell phone search warrants, requiring real limits tied to the crime under investigation rather than boilerplate language. Prosecutors, defense lawyers, and magistrates statewide will need to rethink how warrants for phone data are drafted and reviewed.

Affirmed

1. The court applied the Fourth Amendment's particularity requirement, which says a search warrant must specifically describe what officers are looking for so they don't end up rummaging through someone's belongings without limits.
2. The warrant here authorized seizure of 'any and all stored electronic information' on Wilson's phones, and the preprinted form language the State pointed to as limiting actually just restated that everything found would count as evidence, adding no real boundary.
3. The court compared this warrant to prior cases where warrants it had upheld contained genuine limiting language (sometimes called residual clauses) tying the search to specific crimes, and found this warrant lacked any such limitation.
4. Because the warrant gave officers no meaningful guidance about what data was actually connected to the crimes charged, the court concluded it authorized a general search rather than a targeted one, making it unconstitutional.
5. The court rejected the State's argument that the good-faith exception (which protects police who reasonably relied on binding appellate precedent) applied, because no prior Georgia precedent actually approved this kind of unlimited warrant, so there was nothing to rely on in good faith.

• cell phone search warrant
• Fourth Amendment
• motion to suppress
• murder case
• particularity requirement