Larry Darnell Young v. State of Florida, 394 So.3d 1174

Larry Darnell Young was convicted of manslaughter and attempted manslaughter in connection with a shooting that resulted from an argument involving his girlfriend; a young child was killed by a stray bullet.
Law enforcement initially obtained a warrant to search Young's Facebook account for homicide evidence, but the trial court suppressed this evidence after finding insufficient probable cause for the warrant.
Prosecutors then used a separate set of Facebook records previously obtained for an unrelated retail theft investigation (the “Theft Warrant”), and a detective searched these records for evidence relevant to the homicide, without seeking a new warrant.
The trial court denied Young’s motion to suppress evidence obtained from this warrantless search, invoking the good-faith exception to the Fourth Amendment exclusionary rule.
The Facebook evidence tying Young to the shooting included private messages and a photo of Young with a gun matching the weapon used.
On appeal, Young challenged the admission of Facebook evidence, arguing it was unlawfully obtained and should have been excluded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of Facebook records for homicide evidence violated the Fourth Amendment.	Search violated Fourth Amendment; detective needed a new warrant.	Original Theft Warrant allowed review; all records lawfully possessed.	Search violated Fourth Amendment; privacy interest exists in nonpublic Facebook messages.
Whether the good-faith exception to the exclusionary rule applies.	Not objectively reasonable; lack of binding precedent isn't good faith.	Officer acted in good faith; absence of clear law justified reliance.	Good-faith exception not applicable; lack of precedent does not constitute good faith, nor did warrant cover unrelated crime.
Whether use of evidence outside the scope of the Theft Warrant was permissible.	Use exceeded the authorized scope; only theft/fraud investigation allowed.	Warrant for Facebook records allowed full search.	Warrant scope limited to theft/fraud; searching for homicide evidence exceeded scope.
Whether admission of Facebook evidence was harmless error.	Evidence was critical to identity/proof; not harmless.	Ample other evidence; any error was harmless.	Error was not harmless; Facebook evidence was important to conviction.

Riley v. California, 573 U.S. 373 (2014) (cell phone data protected by Fourth Amendment; warrant required to search digital content)
Herring v. United States, 555 U.S. 135 (2009) (exclusionary rule only applies to sufficiently deliberate/culpable police conduct)
Davis v. United States, 564 U.S. 229 (2011) (good-faith exception applies when police act on objectively reasonable belief)
Leon, 468 U.S. 897 (1984) (good-faith exception for officers relying on a magistrate's warrant)
California v. Ciraolo, 476 U.S. 207 (1986) (reasonable expectation of privacy key to Fourth Amendment protection)
State v. Eldridge, 814 So. 2d 1138 (Fla. 1st DCA 2002) (particularity requirement for describes items in a search warrant)
Carlton v. State, 449 So. 2d 250 (Fla. 1984) (particularity requirement bars exploratory searches)