State of Minnesota v. Arthur Senty-Haugen, A16-109

Arthur Senty-Haugen, civilly committed as an SDP/SPP at MSOP, was found possessing a Samsung Galaxy S5 in violation of MSOP contraband policy.
MSOP staff seized the phone; DHS IT could not unlock it, so MSOP sent it to an outside forensic investigator who extracted messages showing Senty-Haugen paid a staffer $3,000 to smuggle the phone.
Those messages led to a bribery charge; Senty-Haugen moved to suppress evidence from the warrantless search of the phone’s digital contents.
The district court denied suppression, finding Senty-Haugen had a diminished privacy interest as an involuntary civil patient and that the search was reasonable under a Bell balancing test given security and rehabilitation concerns.
Senty-Haugen pleaded to preserve the suppression ruling and was sentenced to 26 months with 383 days’ credit; he appealed denial of suppression and denial of 22 days additional jail credit.
The court affirmed both rulings: (1) MSOP’s warrantless search of the phone’s contents was reasonable under Bell given institutional security risks, and (2) the court properly awarded credit beginning October 3, 2014.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MSOP’s warrantless search of phone data violated Fourth Amendment (suppression)	Senty-Haugen: Riley protects cell-phone data; he retained reasonable privacy and no exigency or policy authorization justified a warrantless search	State/MSOP: Riley limited to arrestees; as an involuntary civil patient he has a diminished expectation of privacy and institutional security justified the search	Denied suppression: court applied Bell balancing for detained persons, found search reasonable given security threats from contraband phone and MSOP policies
Whether Senty-Haugen was entitled to 22 days additional jail credit	Senty-Haugen: Probable cause and completed investigation existed Sept 12–Oct 3, so credit should start Sept 12	State: Contends custody did not begin then; prosecutor conceded credit back to Oct 3	Court affirmed credit from Oct 3, 2014: prosecution had substantially completed investigation and probable cause by that date under Clarkin test

Riley v. California, 134 S. Ct. 2473 (holding warrant generally required to search data on a cell phone)
Bell v. Wolfish, 441 U.S. 520 (establishing balancing test for reasonableness of searches of detainees and deference to institutional security needs)
State v. Barajas, 817 N.W.2d 204 (Minn. Ct. App. recognizing Fourth Amendment protection for cell-phone digital contents)
Serna v. Goodno, 567 F.3d 944 (Eighth Circuit treating civilly committed sex offenders as having diminished privacy similar to pretrial detainees)
State v. Clarkin, 817 N.W.2d 678 (describing standards for awarding jail credit)