State v. Cannon, 450 P.3d 567

Police obtained an HP laptop from a pawn shop that contained lewd images of children; the laptop had been sold to and then resold by defendant within a two‑week period. Pawn shop staff said the laptop had been wiped before the sale and then later had the images.
Detective Cummings learned defendant is a registered sex offender on parole, with a parole condition prohibiting possession of internet‑capable devices; the parole officer arrested defendant and reported a Samsung smartphone in defendant’s parked vehicle.
Cummings’s affidavit included training‑and‑experience statements that persons who possess/distribute child pornography commonly store images on cell phones, computers, thumb drives, SD cards, gaming systems, and other electronic devices.
The search warrant authorized seizure and forensic examination of “any” cell phones, “all” computers (laptops, tablets, iPads, iPods), and “any and all” other electronic storage devices found in defendant’s vehicle.
Execution of the warrant yielded two Samsung phones and other devices; one Samsung phone contained seven images of child pornography and the pawn‑shop HP laptop (already in custody) contained one image.
The trial court suppressed the seven images from the Samsung phone, ruling the warrant was overbroad; the state appealed and the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant was overbroad because it authorized searching all electronic devices found in defendant’s car	The affidavit’s totality (lewd images on HP laptop, defendant’s parole violation, Walmart conduct) plus Cummings’s training/experience supported probable cause that any device would contain child pornography	Affidavit only established probable cause as to the HP laptop and at most one known phone; warrant’s authorization to search “any” devices exceeded what the affidavit supported	Warrant was overbroad; affidavit did not supply probable cause that evidence would probably be on every enumerated device; suppression affirmed
Whether officer’s training/experience statements supplied the necessary nexus to justify searching all listed devices	Training/experience statements show it is common to store/distribute child porn on mobile and other devices, supporting a conclusion that any device could contain evidence	The training statements were generic and not sufficiently tied to facts of this case to establish probable cause for every device; they permit only the possibility, not a probability, that all devices contain evidence	Training/experience statements alone (as presented) were insufficient to create probable cause for the broad array of devices authorized by the warrant

State v. Burnham, 287 Or App 661 (court of appeals 2017) (warrant authorizing forensic search of many devices was overbroad where affidavit supported probable cause only as to a particular phone)
State v. Friddle, 281 Or App 130 (court of appeals 2016) (officer training statements and a link to one device did not establish probable cause to search numerous other devices)
State v. Mansor, 363 Or 185 (Or. 2018) (warrant to search digital devices must be supported by probable cause that evidence will be found on the device)
State v. Villagran, 294 Or 404 (Or. 1982) (police are not limited to searching only the single most promising place when probable cause supports searching other locations, but probable cause must exist for each target)
State v. Sagner, 12 Or App 459 (court of appeals 1973) (probable cause review confined to the four corners of the affidavit and reasonable inferences drawn from it)