Good-Faith Reliance and the “Minimal Nexus” Standard for Cell Phone Warrants in the Sixth Circuit: Commentary on United States v. Tanzil

Good-Faith Reliance and the “Minimal Nexus” Standard for Cell Phone Warrants in the Sixth Circuit:
Commentary on United States v. Jameel Anthony Dion Tanzil

I. Introduction

United States v. Tanzil, No. 25‑1102 (6th Cir. Nov. 20, 2025) (not recommended for publication), sits at the intersection of two major Fourth Amendment developments:

  • The rapidly evolving law governing search warrants for cell phones, and
  • The Leon good-faith exception and its “bare-bones” limitation.

The Sixth Circuit expressly acknowledges that it has not yet resolved a core question: what kind of “nexus” between a defendant’s cell phone and suspected criminal activity is required to establish probable cause to search the phone. Yet the panel again declines to decide that constitutional question and instead reverses on the narrower ground that officers acted in objectively reasonable good faith.

In doing so, the court reinforces and extends a line of cases emphasizing that, even if a warrant later proves unsupported by probable cause, the exclusionary rule does not apply when the affidavit shows at least a “minimally sufficient nexus” between the device and the crime. This case is a significant application of that doctrine to the digital context, especially given the breadth of the cell phone warrant at issue.

Although the opinion is unpublished and thus not binding precedent, it is a strong indicator of how the Sixth Circuit will treat future motions to suppress evidence obtained from cell phones where the probable-cause nexus is thin but not wholly absent.

II. Factual and Procedural Background

A. The Underlying Events

Jameel Tanzil had four prior felony convictions dating back to 2014 and was on probation when he allegedly became involved in a series of firearm-related incidents in Pontiac, Michigan:

  1. October 28, 2023 – Homicide of a Sixteen-Year-Old Girl
    A 16-year-old girl was shot and killed. A witness observed Tanzil firing a gun in her direction. Police arrested Tanzil and seized his iPhone. After receiving Miranda warnings, he:
    • Admitted handling guns while filming a music video earlier in October,
    • Admitted being present at the scene of the shooting but denied involvement, and
    • Claimed his phone contained information proving his innocence but refused to consent to a search.
  2. September 2023 – Hookah Lounge Shooting
    Roughly a month earlier, a separate shooting occurred in the parking lot of a hookah lounge:
    • Surveillance video showed Tanzil leaving the lounge with a gun and engaging in a firefight with another person.
    • Location data from Tanzil’s GPS ankle tether placed him at the scene.
  3. August 2023 – Attempted Firearm Purchase and Subsequent Theft
    In August 2023, while at work:
    • Tanzil tried to purchase four firearms from a coworker during a break.
    • He photographed the coworker’s guns using a cell phone and sent the pictures via Snapchat to another contact.
    • After the coworker discovered that Tanzil was on probation (seeing his GPS tether), he refused to complete the sale.
    • The next day, the coworker’s guns were stolen from his car; Tanzil was the only person who knew the guns were in the car, making him a suspect.

As a convicted felon, Tanzil was barred from possessing firearms or ammunition under 18 U.S.C. § 922(g)(1). These episodes led law enforcement to suspect that he had violated that statute and possibly committed related theft and fraud offenses.

B. The State and Federal Warrants for the Cell Phone

Two separate teams sought warrants to search Tanzil’s phone:

  1. State Warrant
    A state affidavit sought broad access to the phone in an investigation of Tanzil as a felon in possession of a firearm. The affidavit’s support for probable cause was largely conclusory, with minimal factual detail. The state court nonetheless issued the warrant.
  2. Federal Warrant
    ATF agents later applied for a federal search warrant targeting the same phone, based on an investigation into:
    • Theft,
    • Fraud, and
    • Felon-in-possession offenses.
    The federal affidavit:
    • Described the Pontiac shootings and Tanzil’s post-arrest statements (including his admission that the phone supposedly contained exculpatory evidence).
    • Recounted his use of Snapchat to photograph and transmit images of the coworker’s guns shortly before they were stolen.
    • Explained that modern cell phones store location data that can reconstruct a user’s past movements.
    • Mentioned prior, unrelated insurance fraud involving an IP address tied to Tanzil.
    • Outlined the affiant’s training and experience regarding how suspects use phones in criminal schemes (communication, planning, storage of evidence, etc.).
    A federal magistrate judge approved a warrant that:
    • Limited the data to be seized to a three-month window, and
    • Authorized extensive access to:
      • Call logs;
      • Bank and financial records;
      • Location data;
      • Internet browsing history;
      • Text messages;
      • Notes apps; and
      • Social media and messaging apps such as Snapchat, “to the extent” they contained evidence of gun and fraud offenses.

Agents executed the federal warrant, and evidence obtained from the phone led to a federal grand jury indictment charging Tanzil with being a felon in possession of ammunition, in violation of § 922(g)(1).

C. District Court Suppression Ruling

Tanzil moved to suppress the fruits of both the state and federal warrants, arguing primarily that:

  • Both warrants lacked probable cause because the affidavits did not provide a sufficient nexus between the phone and the criminal activity, and
  • The good-faith exception should not apply because no reasonable officer could rely on such defective warrants.

The district court agreed:

  • It held that the state and federal affidavits failed to establish any meaningful factual connection between Tanzil’s phone and the firearms crimes.
  • It further concluded that any objectively reasonable officer would have recognized this deficiency, so the Leon good-faith exception was unavailable.

The government appealed only as to the federal warrant.

III. Summary of the Sixth Circuit’s Opinion

The Sixth Circuit reverses the district court’s suppression order and remands. Its key holdings are:

  1. The panel reiterates that the Sixth Circuit has not yet resolved the specific Fourth Amendment question:
    What is the required probable-cause “nexus” for a warrant to search a cell phone?
    It acknowledges two competing standards (discussed in United States v. Rolling) but expressly declines to choose between them.
  2. Instead, the court decides the case under the good-faith exception of United States v. Leon, 468 U.S. 897 (1984), holding that:
    • Even if the warrant lacked probable cause,
    • The affidavit was not “so lacking in indicia of probable cause” as to be “bare bones.”
    • There was at least a “minimally sufficient nexus” between the alleged crimes and the cell phone to permit objectively reasonable reliance on the magistrate’s decision.
  3. The panel finds that the district court erred by conclusorily rejecting good faith without undertaking the more detailed analysis Sixth Circuit precedent requires, particularly in complex (“frothy”) nexus cases.
  4. Because the good-faith exception applies, the exclusionary rule does not, and the evidence from the phone remains admissible. The case is remanded for further proceedings on the merits.

The opinion therefore leaves the underlying probable-cause question unresolved but significantly reinforces the breadth of the good-faith exception in digital search cases.

IV. Detailed Analysis

A. The Fourth Amendment Framework and the Nexus Requirement

The court situates its analysis within familiar Fourth Amendment principles:

  • The Fourth Amendment authorizes warrants only upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched and the items to be seized.
  • Probable cause requires “reasonable grounds for belief, supported by less than prima facie proof but more than mere suspicion,” citing United States v. Abboud, 438 F.3d 554, 571 (6th Cir. 2006), and United States v. Padro, 52 F.3d 120 (6th Cir. 1995).
  • Under Dalia v. United States, 441 U.S. 238 (1979), the warrant applicant must demonstrate probable cause that “the evidence sought will aid in a particular apprehension or conviction for a particular offense.”
  • Applying the totality of the circumstances test from Florida v. Harris, 568 U.S. 237 (2013), courts evaluate whether there is a “fair probability” that evidence of a crime will be found at the place identified in the warrant.
  • A magistrate’s probable-cause finding receives “great deference.” Reviewing courts ask only whether the magistrate had a “substantial basis” for concluding that probable cause existed, per United States v. Allen, 211 F.3d 970, 973 (6th Cir. 2000) (en banc).

Central to this case is the “nexus” requirement: there must be a meaningful relationship between the place to be searched (here, the cell phone) and the evidence sought. This principle, rooted in United States v. Carpenter, 360 F.3d 591, 594 (6th Cir. 2004) (en banc), and United States v. Van Shutters, 163 F.3d 331 (6th Cir. 1998), is restated in Ellison v. Balinski, 625 F.3d 953, 958 (6th Cir. 2010): the affidavit must provide a substantial basis to believe the items will be found in the place to be searched.

B. Cell Phones and the Unsettled Nexus Standard

The panel squarely recognizes that cell phones are different from traditional physical repositories of evidence. Citing:

  • Riley v. California, 573 U.S. 373 (2014), which describes cell phones as “a digital record of nearly every aspect of [our] lives” and emphasizes their pervasive, quasi-anatomical role in modern life.
  • United States v. Griffith, 867 F.3d 1265 (D.C. Cir. 2017), which notes that cell phones can be a “fruitful source of evidence,” especially when crimes involve communication with accomplices.

The upshot: cell phones both expand investigative possibilities and raise heightened privacy concerns. Against this backdrop, courts must decide how much particularized evidence is required to justify searching a phone.

The Sixth Circuit, referencing United States v. Rolling, No. 23‑1045, 2024 WL 4512532 (6th Cir. Oct. 17, 2024), identifies two competing nexus tests:

  1. Use-Based Nexus (Sheckles Standard)
    Borrowed from United States v. Sheckles, 996 F.3d 330 (6th Cir. 2021):
    The affidavit must contain factual allegations that the phone itself is being used in connection with criminal activity.
    This is a stricter test, demanding some direct link between the device and the crime.
  2. Traditional “Fair Probability” Nexus
    Mirroring standard probable-cause analysis:
    The affidavit must allege a fair probability that the phone will aid in a particular investigation and disclose evidence of criminal activity.
    This may allow inferences from general patterns of phone use plus a suspect’s alleged participation in the crime, even without proof that the phone was used during the offense.

The court explicitly notes this doctrinal tension but, as in Rolling, finds it unnecessary to choose between them because the case can be resolved under good faith. This move continues a recent trend: avoiding potentially far-reaching Fourth Amendment rulings when Leon can decide the case.

C. The Leon Good-Faith Exception and Its Limits

United States v. Leon, 468 U.S. 897 (1984), is the foundation for the good-faith doctrine. Leon holds:

  • When officers obtain and execute a warrant from a neutral magistrate, but the warrant later turns out to lack probable cause, the evidence need not be excluded if the officers acted in objective good faith—that is, in reasonable reliance on the warrant’s validity.
  • The rationale is deterrence: the exclusionary rule is meant to deter police misconduct, not judicial errors. When officers do what they are supposed to—seek judicial approval—deterrence is minimal, so suppression is typically inappropriate.

Leon, however, recognizes four scenarios where good faith does not save the warrant:

  1. False or Reckless Affidavit
    The magistrate is misled by an affidavit containing statements the affiant knew were false or would have known were false but for reckless disregard for the truth.
  2. Abandonment of Judicial Role
    The magistrate wholly abandons his or her neutral role, acting as a rubber stamp.
  3. “Bare-Bones” Affidavit
    The affidavit is so lacking in indicia of probable cause that no reasonable officer could rely on it. This is the critical category in Tanzil.
  4. Facially Deficient Warrant
    The warrant is so facially defective—for example, failing to specify the place to be searched or the items to be seized—that it could not reasonably be presumed valid.

Here, only the third Leon exception is at issue: whether the affidavit was “so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable.”

D. What Counts as “Bare Bones” in the Sixth Circuit?

Sixth Circuit precedent provides a detailed framework for what makes an affidavit “bare bones”:

  • In United States v. Washington, 380 F.3d 236, 241 n.4 (6th Cir. 2004), and Van Shutters, the court defined a bare-bones affidavit as one that merely states “suspicions, or conclusions, without providing some underlying factual circumstances” regarding the basis of knowledge, veracity, or reliability.
  • United States v. Laughton, 409 F.3d 744 (6th Cir. 2005), held that where an affidavit provides “absolutely no facts” to support probable cause, it is bare bones and cannot be rescued by good faith.
  • United States v. Christian, 925 F.3d 305 (6th Cir. 2019) (en banc), reaffirmed that bare-bones affidavits contain only unadorned suspicions or conclusory assertions.
  • By contrast, Carpenter and United States v. White, 874 F.3d 490 (6th Cir. 2017), introduced the notion of a “minimally sufficient nexus”. If the affidavit contains even a “modicum of evidence” connecting the place to be searched with the crime, it is not bare bones—even if this evidence falls short of probable cause.
  • The en banc decision in United States v. Sanders, 106 F.4th 455 (6th Cir. 2024), crystallized this forgiving standard:
    When there is a “modicum of evidence, however slight” that shows “some connection, regardless of how remote” between the criminal activity and the place to be searched, a “minimally sufficient nexus” exists.

This doctrinal move is crucial: probable cause and good faith are different thresholds.

  • Probable cause requires a “fair probability” that evidence will be found in the place searched.
  • Good faith is satisfied by something less: if there is some factual content—not mere boilerplate or speculation—connecting the place and the crime, then reasonable officers may rely on the magistrate’s determination even if a reviewing court later finds probable cause lacking.

Tanzil applies this distinction to a cell-phone warrant.

E. Application of Good Faith in Tanzil

The district court had concluded, with little explanation, that “an objectively reasonable law enforcement officer would have recognized [the] deficiency” in the affidavit and therefore the Leon good-faith exception did not apply.

The Sixth Circuit faults this analysis as incomplete and inconsistent with its recent precedent dealing with “frothy” nexus questions, citing:

  • United States v. Reed, 993 F.3d 441, 452 (6th Cir. 2021), and
  • United States v. Rolling, 2024 WL 4512532, at *4 (6th Cir. 2024), which describe cases where the affidavit doesn’t show a direct factual connection but relies on inferences, making the Leon inquiry nuanced rather than straightforward.

Analyzing the affidavit as a whole and under the totality of the circumstances (citing United States v. Greene, 250 F.3d 471, 479 (6th Cir. 2001)), the panel concludes that it is not bare bones.

The following features, taken together, supply the “modicum of evidence” and “minimally sufficient nexus” needed for good faith:

  1. Tanzil’s Own Statements About the Phone
    He told officers that:
    • He had handled guns earlier in the month while filming a music video, and
    • His phone contained evidence showing he did not commit the October 28 homicide.
    Even though he refused consent, this admission directly linked the phone to the investigation of a serious gun crime. At minimum, it suggested the phone likely held data (messages, photos, location records) relevant to the events surrounding the shooting.
  2. Snapchat Photos of Guns Later Stolen
    The affidavit described how:
    • In August, Tanzil photographed his coworker’s firearms on a phone and transmitted them via Snapchat,
    • The coworker then declined to sell the guns after learning that Tanzil was on probation, and
    • The guns were stolen from the coworker’s car the next day, with Tanzil being the only person who knew they were in the car.
    On appeal, Tanzil himself conceded it was reasonable to infer that a cell phone was used to take those Snapchat photos and that such data would still be associated with his Snapchat account even if he changed or upgraded devices. This supports a reasonable belief that evidence relevant to firearms offenses and theft might be found on his phone or in data accessible via that device.
  3. Location Data and Cell Phone Functionality
    The affidavit explained that:
    • Modern phones collect and maintain detailed location data,
    • That data can help reconstruct a suspect’s movements, and
    • This is particularly relevant when investigating crimes like the shootings in Pontiac, where location and timing are contested.
    Combined with Tanzil’s statements about being present at the homicide scene and his GPS ankle tether records for the lounge shooting, it was reasonable to infer that the phone might contain corroborating or contradicting location data.
  4. Affiant’s Training and Experience, Used Properly
    The ATF agent described his experience with:
    • How suspects use phones for coordination, communication, and record-keeping in criminal schemes, and
    • How phone searches regularly uncover evidence of firearms and fraud offenses.
    The Sixth Circuit has warned that an officer’s training and experience, standing alone, is an “archetypal example” of a bare-bones affidavit (United States v. Merriweather, 728 F. App’x 498, 506 (6th Cir. 2018)). But in Tanzil, those generalizations were anchored to specific, case-related facts (Tanzil’s statements, his Snapchat use, and the shootings).

Taken together, these allegations amount to more than mere “suspicions or conclusions.” They provide factual content linking Tanzil’s phone to the firearms, theft, and fraud investigations. While they might be debated as insufficient for probable cause under either nexus test, they are enough to satisfy the low threshold for good faith:

  • Under Sanders, a “modicum of evidence, however slight” that creates “some connection, regardless of how remote” is enough to avoid the bare-bones label.
  • Under White, reasonable inferences that may not establish probable cause can still render reliance on a warrant “objectively reasonable” for Leon purposes.

The panel emphasizes that a “nonlawyer officer,” viewing the affidavit as a whole, could reasonably rely on the magistrate’s determination of probable cause. Therefore:

  • The affidavit is not bare bones within the meaning of Leon’s third exception.
  • The officers’ reliance on the warrant was objectively reasonable.
  • The good-faith exception applies, and suppression is inappropriate even if probable cause was lacking.

F. Precedents and Their Influence

Key precedents and how they shaped the ruling:

  1. Leon and Its Progeny
    Leon provides the core framework: suppression is a last resort, reserved for deliberate, reckless, or grossly negligent police conduct. Tanzil applies Leon’s third exception (bare bones) as refined in:
    • Laughton and Christian (defining bare-bones affidavits),
    • White (allowing lesser inferences to sustain good faith), and
    • Sanders (articulating the “modicum of evidence” standard and the reasonable “nonlawyer officer” perspective).
  2. Nexus and Inference Cases
    Carpenter and its progeny (e.g., Greene, White, Reed) support the use of reasonable inferences to tie locations (or, by extension, devices) to suspected criminal activity, especially in the context of repeat offenders and weapons crimes. Rolling imports that reasoning into the cellphone context and frames the unresolved choice between the two nexus tests that Tanzil again sidesteps.
  3. Digital-Privacy Authorities
    Riley v. California and Griffith provide the conceptual backdrop: phones are deeply intrusive yet often central to criminal activity. Tanzil acknowledges this tension but resolves the case on remedial grounds (good faith) rather than by enhancing or diminishing the nexus burden for digital warrants.
  4. Standards of Review and Good-Faith Deference
    United States v. Hines, 885 F.3d 919 (6th Cir. 2018), and United States v. O’Neill, 94 F.4th 531 (6th Cir. 2024), remind that probable-cause and good-faith determinations are legal questions reviewed de novo. That framing allowed the panel to independently reassess the district court’s brief rejection of good faith and conclude it was legally erroneous.

G. The Opinion’s Place in Sixth Circuit and National Jurisprudence

Although designated “not recommended for publication,” Tanzil is doctrinally important in at least three respects:

  1. Reinforcement of a Very Low Threshold for Good Faith
    The case builds directly on Sanders and White to reaffirm that:
    • Even where the nexus is debatable or weak,
    • As long as the affidavit contains some case-specific factual allegations connecting the phone to the crimes,
    • Good faith will likely save the search from suppression.
  2. Continued Avoidance of a Definitive Cell Phone Nexus Standard
    By again declining to choose between the Sheckles-style “use-based” nexus and a looser “fair probability” standard, the court:
    • Leaves practitioners and magistrates without a settled rule on how much linkage is required to search a phone in the first instance.
    • But signals that, whatever standard emerges, Leon’s good-faith exception will cast a wide shadow over most close cases.
  3. Digital Context, Traditional Tools
    Tanzil shows the court treating cell-phone searches through the existing Leon and nexus framework rather than crafting a new digital-specific good-faith standard. The message is that smartphones, despite their unique privacy implications recognized in Riley, will not automatically receive heightened protection at the remedial (exclusionary-rule) stage absent clearer police misconduct.

V. Complex Concepts Simplified

A. Probable Cause vs. Good Faith

  • Probable Cause answers: “Is there enough reason to believe evidence of a crime will be found here?”
    • Threshold: fairly strong but not certain – more than suspicion, less than proof.
    • Focus: objective facts and reasonable inferences.
  • Good Faith answers: “Even if the warrant turns out to be defective, did officers act reasonably in trusting it?”
    • Threshold: lower than probable cause.
    • If officers present specific facts to a judge, obtain a warrant, and the affidavit is not purely conclusory or fabricated, courts usually find good faith.

In short: a warrant can lack probable cause but still be saved by good faith if officers reasonably relied on it.

B. The Nexus Requirement

The “nexus” is the link between the crime and the thing or place to be searched. For a phone warrant, the key questions are:

  • Is there some reason to believe the phone was used in the crime (calls, texts, photos)?
  • Or, more broadly, is it reasonably likely that the phone contains evidence about the crime (location data, messages planning the crime, etc.)?

The unresolved debate in the Sixth Circuit is whether:

  • The government must show actual use of the phone in the crime (Sheckles view), or
  • It is enough to show a fair probability that evidence of the crime is on the phone, given how people typically use phones (Rolling’s broader view).

C. “Bare-Bones” Affidavits

An affidavit is “bare bones” when it essentially says:

“We think the suspect is guilty and believe evidence may be found in this place,”

but does not explain why with any specific facts.

Examples of bare-bones features:

  • Generic claims like “drug dealers keep evidence at home” with no facts tying this suspect to this home.
  • Statements based solely on an officer’s “experience and training,” without case-specific details.
  • Speculative statements like “evidence could be anywhere the suspect has been” without more.

In contrast, an affidavit avoids the bare-bones label when it:

  • Provides specific incidents (dates, actions, statements by the suspect) and
  • Explains how those facts suggest evidence will be found at the location or on the device.

D. “Not Recommended for Publication”

In the Sixth Circuit, unpublished opinions are:

  • Not binding precedent on later panels, but
  • May be cited as persuasive authority.

So, while Tanzil does not change the law in a formal sense, it is a strong signal of how the court is likely to analyze similar cases, especially because it heavily relies on binding en banc decisions like Sanders and Christian.

VI. Practical Implications

A. For Law Enforcement

  • Officers seeking cell-phone warrants should:
    • Include concrete, case-specific facts connecting the phone to the crimes (e.g., admissions, observed use, social media posts, location evidence).
    • Avoid relying only on boilerplate assertions about how criminals “typically” use phones.
    • Articulate why phone data (location history, communications, photos) are likely relevant to the particular incidents under investigation.
  • Where such factual content exists, Tanzil suggests that even close calls on probable cause will likely be protected by Leon’s good-faith exception.

B. For Defense Counsel

  • Challenging a cell-phone warrant on probable-cause grounds alone may not be sufficient, given the breadth of the good-faith doctrine. Counsel must:
    • Argue that the affidavit is truly bare bones—i.e., lacking meaningful factual support.
    • Highlight any misstatements, omissions, or reckless disregard for the truth (to trigger the first Leon exception).
    • Stress overbreadth and lack of particularity where the warrant essentially authorizes a digital “general search.”
  • Given Tanzil’s emphasis on modest factual linkages as sufficient for good faith, successful suppression arguments may increasingly hinge on demonstrating affirmative misconduct or facial defects, rather than fine-grained disputes about the sufficiency of the nexus.

C. For Magistrate Judges

  • Even though good faith might later save a warrant, magistrates remain the frontline protection for privacy. Tanzil underscores:
    • The importance of demanding concrete, case-specific facts tying the phone to the offense.
    • The need to narrowly tailor the scope of digital warrants (time frames, types of data) to reduce the risk of overbreadth and to align with Riley’s privacy concerns.

D. For the Development of Fourth Amendment Doctrine

  • Doctrinal Drift Toward Leon:
    • As in Rolling, Tanzil resolves a complex digital-privacy issue at the level of remedies, not rights.
    • This may delay or blunt the formation of clear, substantive rules about when phones can be searched, while entrenching a robust good-faith shield for law enforcement.
  • Future Cell-Phone Nexus Cases:
    • Eventually, a published Sixth Circuit decision—or the Supreme Court—will likely need to resolve the tension between the two competing nexus standards.
    • Until then, Tanzil suggests that, in close cases, courts will default to admitting evidence under Leon as long as the affidavit contains more than mere boilerplate and speculation.

VII. Conclusion

United States v. Tanzil reinforces a central theme of recent Sixth Circuit Fourth Amendment jurisprudence: Leon’s good-faith exception is broad, and the bar for labeling an affidavit “bare bones” is high. Even in the sensitive context of cell-phone searches, the court holds that modest factual connections—such as a suspect’s own statements about the phone, specific social media use involving weapons, and the phone’s inherent capacity to store relevant location and communication data—are enough to create a “minimally sufficient nexus” for good-faith reliance.

The panel explicitly leaves unresolved the underlying constitutional question about what nexus is required to establish probable cause for a cell phone warrant. Instead, it relies on the remedial doctrine of good faith to reverse suppression. This approach preserves flexibility for future panels but also means that, in practice, many digital searches will stand even when their probable-cause foundations are contestable, so long as officers have presented some concrete, case-specific facts to a neutral magistrate.

In the broader legal context, Tanzil is a persuasive but nonbinding signal that, within the Sixth Circuit, digital evidence obtained under a facially valid warrant will rarely be excluded unless the affidavit is purely conclusory, deliberately misleading, or the warrant is facially defective. It thus underscores the need for careful drafting of affidavits, vigilant judicial review of digital warrants, and strategic, fact-intensive advocacy by defense counsel seeking suppression in an era where cell phones are both indispensable to modern life and central to contemporary law enforcement.

Case Details

Year: 2025
Court: Court of Appeals for the Sixth Circuit

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