Moats v. State, 148 A.3d 51

Background

In January 2015, 18-year-old Timothy Moats gave marijuana and suboxone to three teenagers; one of them (A.D.C.) later reported a sexual assault at a party.
Moats admitted distributing drugs and being present at the party; police obtained an arrest warrant for drug-related offenses and arrested him on January 23, 2015.
Officers seized Moats’s cell phone incident to the arrest; Moats was released the next day but the phone was retained by police as potentially evidentiary.
On January 26, 2015, Sergeant Zimmerman obtained a search warrant for the phone based on interviews and his training/experience that criminals communicate via cell phones.
The warrant search revealed sexually explicit photos and a video of Moats’s then-15-year-old girlfriend; Moats was charged with possession of child pornography and later convicted on an agreed statement of facts.
Moats moved to suppress the phone data, arguing (1) the continued retention after release lacked probable cause and (2) the warrant affidavit failed to establish a nexus between the offenses and the phone; the circuit court denied suppression and the appellate court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrantless seizure and two-day retention of Moats’s phone unlawful?	Moats: retention after release lacked probable cause and violated Fourth Amendment.	State: phone was lawfully seized incident to arrest and reasonably retained while obtaining a warrant.	Held: Seizure incident to arrest lawful; retention to prevent destruction and obtain a warrant was reasonable.
Did the search-warrant affidavit establish a sufficient nexus between the alleged crimes and the phone to support issuance?	Moats: affidavit’s generalized assertion that criminals use phones, without more, did not provide a substantial basis for a warrant.	State: affidavit (confessions, witness statements, and officer’s training/experience) supplied a commonsense nexus that evidence likely resided on the phone.	Held: Affidavit provided a substantial basis for the magistrate to infer evidence would be on the phone; warrant valid.
If the warrant were insufficient, does the good-faith exception apply?	Moats: (argues warrant defective, suppression appropriate).	State: Sergeant Zimmerman objectively believed the warrant was supported and relied on magistrate; Leon good-faith exception applies.	Held: Even if warrant defective, Leon good-faith exception would admit the evidence.
Did the suppression court apply correct standard of review?	Moats: trial court may have applied incorrect or imprecise standards at the hearing.	State: any imprecision did not affect outcome; appellate court reviews legal conclusions de novo and finds no error.	Held: Any misarticulation was immaterial; appellate de novo review confirms denial of suppression was correct.

Key Cases Cited

Riley v. California, 134 S. Ct. 2473 (U.S. 2014) (cell phones hold vast, private data; warrants generally required to search digital contents)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule for defective warrants)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances standard; deference to magistrate; substantial-basis review)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reviewing probable cause and legal questions de novo; factual findings for clear error)
Holmes v. State, 368 Md. 506 (Md. 2003) (probable cause may be inferred from crime type, nature of items sought, opportunity for concealment)
State v. Wallace, 372 Md. 137 (Md. 2002) (standard of review for suppression rulings; view factual record in light most favorable to prevailing party)
Sinclair v. State, 444 Md. 16 (Md. 2015) (discussing Riley and the need for warrants to search cell-phone contents)