State v. Correa, 353 Conn. 338

In December 2017 Sergio Correa exchanged messages with Matthew Lindquist to plan stealing a gun safe from Matthew’s parents’ house; Correa and his sister Ruth traveled to the house and Matthew was killed nearby; Correa and Ruth then entered the house, Correa killed Kenneth and Janet Lindquist, stole items, and set the house on fire.
Police lawfully obtained TextNow messages between Matthew and Correa; on Dec. 28, 2017 police interviewed Correa, then seized his iPhone without a warrant out of concern he would destroy evidence.
Six months later investigators obtained a warrant to search and seize “all data” from Correa’s phone; the warrant listed example categories (calls, texts, photos) but contained no temporal limits.
FBI performed a full extraction; the prosecution introduced GPS data, messages, internet searches and photos from the extraction at trial.
The trial court denied suppression in part but applied severance to limit admissible phone data to a specified December period; Correa was convicted on multiple counts and sentenced to life.
On appeal the Connecticut Supreme Court held the warrant lacked the Fourth Amendment particularity required for cell‑phone searches, that the trial court improperly applied severance, but that admission of the phone evidence was harmless beyond a reasonable doubt; judgment affirmed.

Issue	State's Argument	Correa's Argument	Held
Validity of warrantless seizure of phone after interview	Seizure was justified by fear Correa would destroy data	Seizure lacked probable cause/exigency	Court assumed seizure constitutional for purposes of decision (did not decide)
Particularity of warrant to search “all data” on phone	Warrant incorporated affidavit listing crimes and sample categories; “including but not limited to” is adequate	Warrant was a general warrant: authorized search of all phone contents and lacked time and content limits	Warrant violated Fourth Amendment particularity: failed to limit by content and time; incorporation did not cure that defect
Application of severance doctrine to cure warrant deficiencies	Trial court properly severed and limited timeframe of admissible data	Severance cannot be used to rewrite a warrant or add temporal limits post hoc	Trial court erred: no constitutional portion to salvage; court may not rewrite warrant; severance inapplicable
Harmless‑error analysis for admitted phone evidence	Phone evidence was cumulative and corroborative; error harmless beyond reasonable doubt	Phone evidence was critical corroboration of key witnesses and could have influenced jury	Error was harmless beyond a reasonable doubt: independent, overwhelming evidence corroborated witnesses; phone evidence largely cumulative

Riley v. California, 573 U.S. 373 (2014) (cell phones hold vast personal data and require careful Fourth Amendment limits)
United States v. Purcell, 967 F.3d 159 (2d Cir. 2020) (warrant particularity requires identification of offenses, place, and items by relation to crimes)
State v. Smith, 344 Conn. 229 (Conn. 2022) (warrant to search cell‑phone contents must be limited in scope to content related to probable cause)
State v. Browne, 291 Conn. 720 (Conn. 2009) (discusses incorporation of affidavit and severance doctrine)
Groh v. Ramirez, 540 U.S. 551 (2004) (particularity must appear in the warrant itself; incorporation by reference has limits)
Maryland v. Garrison, 480 U.S. 79 (1987) (particularity limits exploratory searches)
United States v. Sells, 463 F.3d 1148 (10th Cir. 2006) (framework for severance analysis)