Richardson v. State, 282 A.3d 98

On Sept. 28, 2018, a school resource officer (Corporal Young) broke up a fight; Anthony Richardson’s backpack fell, both reached for it, the officer picked it up first, and Richardson immediately fled.
The officer opened the backpack and found a handgun, three cell phones, and Richardson’s school ID; one phone (iPhone 8+) was later identified as stolen in a robbery three days earlier.
Police linked another phone in the backpack (T‑Mobile iPhone SE) to a letgo account used in the robbery and obtained a warrant to search that phone authorizing seizure of “all information … and any other data” on the device without temporal or application-specific limits.
Richardson moved to suppress the warrantless backpack search and the phone search; the trial court denied suppression, Richardson pleaded guilty conditionally, and the Court of Special Appeals affirmed.
The Court of Appeals held (1) Richardson abandoned the backpack when he fled, so the warrantless search was lawful, and (2) the phone warrant failed the Fourth Amendment particularity requirement but the officers reasonably relied on the warrant, so the good‑faith exception applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless search of backpack — abandonment	Richardson: did not abandon; reached to reclaim bag and officer picked it up first	State: flight after officer picked up bag manifested relinquishment of privacy expectation	Held: Richardson abandoned the backpack by fleeing without requesting it back; no Fourth Amendment protection for the subsequent search
Particularity of cell‑phone warrant	Richardson: warrant was a forbidden general/catchall warrant authorizing search of “any and all” data without temporal or content limits	State: warrant incorporated affidavit; affidavit’s facts limited the search to robbery‑related evidence	Held: warrant (and affidavit) used impermissibly broad catchall language and lacked sufficient temporal/application limits — failed particularity requirement
Good‑faith exception to exclusionary rule	Richardson: officers could not reasonably rely on an unduly general warrant	State: officers reasonably relied on warrant as supplemented by incorporated affidavit	Held: executing officers acted objectively reasonably in relying on the incorporated affidavit; Leon good‑faith exception applies, so suppression not required

Riley v. California, 573 U.S. 373 (2014) (cell phones implicate extensive privacy interests; warrants generally required)
Groh v. Ramirez, 540 U.S. 551 (2004) (warrants may be construed with reference to incorporated affidavits)
United States v. Leon, 468 U.S. 897 (1984) (good‑faith exception to exclusionary rule)
Maryland v. Garrison, 480 U.S. 79 (1987) (particularity requirement prevents general searches)
United States v. Jacobsen, 466 U.S. 109 (1984) (definition and limits of government interference with possessory interests)
Carpenter v. United States, 138 S. Ct. 2206 (2018) (advances in technology require vigilance protecting privacy)
Stanberry v. State, 343 Md. 720 (1996) (abandonment relinquishes Fourth Amendment privacy expectation)
Moats v. State, 455 Md. 682 (2017) (cell phone seizure/search issues; concurring views on temporal limits)
Burns v. United States, 235 A.3d 758 (D.C. 2020) (cell‑phone warrants lacking temporal or other meaningful limits violate particularity)