Good-Faith “Minimal Nexus” Sustains Broad Cell-Phone Searches in Drug Warrants, and Warrants May Cover All Phones at a Trafficking Location

Introduction

In United States v. Jared Metzger (6th Cir. Aug. 4, 2026) (unpublished), the Sixth Circuit affirmed the denial of Jared Metzger’s motion to suppress evidence found on his cell phone. The investigation began as a methamphetamine-trafficking case focused on Devin McFaul. Officers obtained warrants to search McFaul’s residence and related locations for drug-trafficking evidence, including “cell phones and their contents.” While examining a phone seized under the drug warrant, an investigator encountered an apparent child-sexual-abuse image, stopped, and obtained a second warrant focused on child pornography. That second search uncovered extensive child sexual abuse material, leading to federal charges.

On appeal, Metzger argued (1) the initial warrant lacked probable cause to search his phone, and (2) the warrant was insufficiently particular because it did not identify which phones could be searched and authorized an overly broad search of phone contents.

Summary of the Opinion

The Sixth Circuit affirmed on two grounds:

  • Good-faith reliance: Even assuming the probable-cause showing was debatable, the affidavit provided a “minimally sufficient nexus” between drug trafficking and Metzger’s phone, allowing officers to rely on the warrant in good faith under United States v. Leon.
  • Particularity (plain-error review): Because Metzger did not raise the particularity challenge below, the court reviewed only for plain error and found none. The warrant’s description of “cell phones and their contents” (with listed content categories) at the premises was sufficiently specific for the circumstances, and Sixth Circuit precedent generally permits seizure and search of entire devices in such investigations.

Analysis

Precedents Cited

Standards of review

  • United States v. Sanders, 106 F.4th 455 (6th Cir. 2024) (en banc): Provided the framework for reviewing suppression rulings—legal conclusions de novo, factual findings for clear error.
  • United States v. Simmons, 129 F.4th 382 (6th Cir. 2025): Reinforced that the appellate court views evidence in the light most favorable to the government when reviewing suppression denials.

Probable cause and the exclusionary rule

  • Illinois v. Gates, 462 U.S. 213 (1983): Supplied the canonical definition of probable cause as a “fair probability” that evidence will be found in a particular place. The panel invoked Gates as the baseline, but ultimately resolved the suppression issue through good faith.
  • Davis v. United States, 564 U.S. 229 (2011): Emphasized that suppression is a deterrence tool, not an automatic remedy for every Fourth Amendment violation. The court used Davis to frame suppression as a “last resort” and to reject deterrence where officers did not act deliberately, recklessly, or with gross negligence.
  • Herring v. United States, 555 U.S. 135 (2009): Contributed the cost-benefit approach—suppression is warranted only when deterrence benefits outweigh the substantial social costs. The panel relied on this balancing to justify applying the good-faith exception.
  • United States v. Leon, 468 U.S. 897 (1984): The centerpiece. The panel applied Leon to hold that reliance on a warrant issued by a neutral judge generally precludes suppression, unless the affidavit is so deficient that reliance is objectively unreasonable.
  • United States v. Reed, 993 F.3d 441 (6th Cir. 2021): Supplied the Sixth Circuit’s “minimally sufficient nexus” test for good-faith reliance and the contrast with “bare bones” affidavits. The panel repeatedly invoked Reed to characterize the bar as “low” and satisfied by “some connection, regardless of how remote.”
  • United States v. Christian, 925 F.3d 305 (6th Cir. 2019) (en banc): Used to describe what a “bare bones” affidavit looks like (“short, conclusory, and self-serving”), and to distinguish the affidavit here as evidentiary and detailed.

Particularity and digital searches

  • United States v. Bass, 785 F.3d 1043 (6th Cir. 2015): Provided (a) plain-error posture for an unpreserved warrant argument and (b) support for broad device searches where evidence can be hidden or mislabeled. The panel used Bass to uphold searching the “entire” phone given practical realities.
  • United States v. Page, 163 F.4th 385 (6th Cir. 2025): Defined the plain-error elements, including that any error must be “obvious or clear” and affect fairness/integrity. This set the high hurdle Metzger could not clear.
  • United States v. Hanna, 661 F.3d 271 (6th Cir. 2011): Contributed the flexible particularity rule: warrants must be “as specific as the circumstances and the nature of the activity under investigation permit.” The panel relied on this to justify not identifying each phone by make/model/owner.
  • United States v. Richards, 659 F.3d 527 (6th Cir. 2011): Noted that the court rejects “most” particularity challenges to warrants authorizing seizure and search of entire computers. The panel treated phones similarly.
  • United States v. Whiteside, 141 F.4th 734 (6th Cir. 2025): Cited for the proposition that the Sixth Circuit has upheld warrants targeting all computers or phones at a particular location, supporting the breadth of the warrant here.
  • United States v. Castro, 881 F.3d 961 (6th Cir. 2018): Used to emphasize that a warrant’s execution is constrained by the crimes for which probable cause was found; officers are not authorized to rummage for unrelated evidence.
  • Riley v. California, 573 U.S. 373 (2014): Invoked for the idea that cell phones function like computers (and are information-dense), supporting the practical need for broad searches while also underscoring why warrants are required in the first place.
  • Mancusi v. DeForte, 392 U.S. 364 (1968): Acknowledged individual privacy interests in shared spaces. The panel accepted the principle but held it did not defeat the warrant because the place and occupants were tied to trafficking activity.

Legal Reasoning

1) Good faith saved the search because the affidavit created a “minimally sufficient nexus”

The court did not need to definitively decide whether the initial warrant established probable cause to search Metzger’s phone; it was enough that officers acted with objective reasonableness in relying on a judge-issued warrant. Applying United States v. Leon through the Sixth Circuit’s gloss in United States v. Reed, the panel asked whether the affidavit was “bare bones” or, instead, provided at least a minimal connection between: (i) drug trafficking and (ii) the phone to be searched.

The panel identified multiple facts supplying that nexus:

  • Metzger was living at McFaul’s residence, which officers linked to meth trafficking and drug paraphernalia in trash pulls.
  • Metzger drove McFaul’s car; a drug dog alerted to narcotics; officers found a document appearing to be a drug ledger.
  • Two would-be buyers reported trying to purchase meth by calling McFaul (linking phones to the trafficking operation).
  • Metzger’s Facebook post tagged McFaul and referenced an officer; officers believed it alerted McFaul and changed his behavior (switching cars). Construing evidence favorably to the government, the court found a fair probability the post was made from a phone—supporting a phone-evidence connection.
  • The affiant detective’s experience (six years in drug investigations) that traffickers use cell phones to facilitate transactions further supported the nexus.

On these facts, the affidavit cleared the “low” good-faith bar: it was not “short, conclusory, and self-serving” under United States v. Christian; it was detailed and tied Metzger’s conduct to the suspected enterprise. The court also rejected the deterrence rationale for suppression because nothing suggested “deliberate, reckless, or grossly negligent” police conduct under Davis v. United States.

2) No plain error in the warrant’s particularity or scope for phones and their contents

Because Metzger did not raise particularity below, the court applied United States v. Bass and United States v. Page: reversal required an obvious error affecting substantial rights and the integrity of proceedings. The panel found none.

The warrant authorized searches of “cell phones and their contents,” listing categories such as contacts, call history, texts, emails, voicemails, pictures, videos, and applications. Under United States v. Hanna, the level of detail required is flexible. The court reasoned that officers often cannot know in advance how many devices are present, their appearance, or their ownership—especially when surveillance-driven investigations avoid entering the property.

The panel also rejected the argument that the warrant had to be limited to McFaul’s devices. The affidavit, in the court’s view, provided a sufficient basis to believe Metzger was involved in the trafficking scheme and that his involvement likely used a phone (the Facebook post and calls used to arrange drug buys). The court cited United States v. Whiteside to support warrants covering all devices at a location where probable cause suggests any device may contain evidence.

Finally, the court addressed overbreadth concerns about searching “entire contents.” Drawing on United States v. Castro, it stressed that the scope was limited by the offenses for which probable cause existed (drug crimes). As a practical matter, United States v. Richards and United States v. Bass recognize that digital evidence can be hidden or mislabeled, often requiring broad examination. The court also credited the officers’ conduct: upon encountering possible child-sexual-abuse imagery, they stopped and sought a new warrant tailored to that crime.

Impact

  • Reinforces the Sixth Circuit’s “low bar” for digital-device good faith: When an affidavit offers multiple, even if individually modest, connections between a suspect, a trafficking scheme, and phone use, Leon/Reed will frequently foreclose suppression.
  • Supports location-based device warrants in shared residences: The decision indicates that warrants may permissibly sweep in phones of co-occupants when the affidavit ties the co-occupant to the criminal activity and explains why phones likely contain evidence.
  • Signals practical acceptance of broad phone searches—within crime limits: By relying on Richards/Bass, the opinion underscores that “search the entire device” authorizations can satisfy particularity so long as they are tethered to specific offenses and not treated as a general warrant.
  • Operational lesson for investigators: The court implicitly rewards the “stop-and-seek-a-new-warrant” approach when an unrelated offense is discovered during a lawful search—helpful for defending subsequent searches against claims of exploratory rummaging.

Complex Concepts Simplified

  • Probable cause: A commonsense showing—based on the totality of circumstances—that there is a fair probability evidence will be found in the place searched.
  • Nexus: The link between the crime and the specific place or item to be searched (here, why a phone is likely to hold drug-trafficking evidence).
  • Good-faith exception: Even if a warrant is later deemed unsupported by probable cause, evidence is not suppressed if officers reasonably relied on a judge-issued warrant, unless the affidavit was obviously deficient.
  • “Bare bones” affidavit: An affidavit so conclusory and unsupported that no reasonable officer could believe it established probable cause.
  • Particularity: The Fourth Amendment requirement that a warrant describe what may be seized with enough specificity to prevent a general exploratory search; what is “enough” depends on circumstances and the evidence sought.
  • Plain-error review: A demanding appellate standard applied when an argument was not preserved in the trial court; the error must be obvious and outcome-affecting, and correction must be necessary to protect the integrity of the proceedings.

Conclusion

United States v. Jared Metzger affirms that, in the Sixth Circuit, a detailed affidavit tying a suspect to a trafficking operation—combined with plausible phone use and an experienced affiant’s explanation—will usually provide the “minimally sufficient nexus” needed for Leon good-faith reliance, even when probable cause to search a phone is contested. The opinion also underscores that warrants may permissibly cover all phones at a trafficking-linked location and authorize broad searches of device contents, so long as execution remains tethered to the specified crimes and investigators do not treat the warrant as a general license to rummage.