United States v. Castro

Following a spate of home-invasion robberies around Dallas, police interrupted a robbery attempt that fit the pattern. The robbers fled on foot. Later that day, police arrested Olaya after finding him in a stolen vehicle with a suspected accomplice. The police inventoried the vehicle’s contents, took custody of a cell phone, and obtained a warrant to search the phone. An officer reviewed the phone's contents by hand, found potentially incriminating evidence, took screenshots, then stored the phone in an evidence storage facility. Texas officials then merged their investigation with a federal investigation focused on a multistate criminal enterprise and transferred the phone to the FBI for analysis. The Bureau searched the phone based on the state warrant. Meanwhile, Texas officers came to suspect that Castro had organized the robberies. They followed a signal coming from a stolen cell phone to a house where Castro lived. Officers watched the home, searched it twice, and conducted a brief search of Castro’s cell phones after obtaining her consent. Based on this evidence, a different Texas judge issued search warrants for Castro’s two phones. Officers searched each phone and found incriminating evidence about the robberies. The federal government charged Castro and Olaya with violating the Racketeer Influenced and Corrupt Organizations Act. The defendants successfully moved to suppress the cell-phone evidence. The Sixth Circuit reversed, finding that each search complied with the Fourth Amendment. View "United States v. Castro" on Justia Law