State v. Ragin, SC21044

Ragin was convicted of murder and criminal possession of a pistol after the shooting death of Max Antione outside a Bridgeport bar. 1
Police obtained a warrant for T-Mobile records for April 20 to May 8, 2017, based on an affidavit describing Noblin's eyewitness account and the missing phone. 2
T-Mobile produced call-identifying information and CSLI in UTC, which included an extra four-hour period from the night before the requested date range. 3
Before trial, Ragin moved to suppress the records as lacking probable cause, lacking particularity, overbroad, and outside the warrant's scope. 4
The trial court denied suppression, and the state used the records with witness testimony to place Ragin near the shooting. 5
The Supreme Court of Connecticut affirmed the conviction. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant lacked probable cause for the requested phone records 7	Ragin said the affidavit showed no nexus to records from April 20-May 8.	The state said the affidavit supported probable cause to obtain CSLI and call data.	Probable cause existed for the requested period. 8
Whether the warrant was sufficiently particular without a time zone 9	Ragin claimed the missing time zone made the warrant ambiguous and overbroad.	The state said the date range sufficiently cabined the search.	The warrant was sufficiently particular. 10
Whether the extra four hours of records had to be suppressed 11	Ragin argued T-Mobile produced records beyond the warrant and police had to discard them.	The state argued the extra data was either not state action or not suppressible.	Suppression was unwarranted; conviction affirmed. 12

State v. Johnson, 354 Conn. 96 (Conn. 2026) (probable-cause and particularity standards for search warrants 13)
State v. Evans, 352 Conn. 794 (Conn. 2025) (probable cause for CSLI and warrant sufficiency 14)
State v. Correa, 353 Conn. 338 (Conn. 2025) (particularity requires definite limits on what may be searched 15)
State v. Montgomery, 254 Conn. 694 (Conn. 2000) (warrants need only be as specific as circumstances permit 16)
State v. Smith, 344 Conn. 229 (Conn. 2022) (warrant for phone contents lacked adequate time limits 17)
Carpenter v. United States, 585 U.S. 296 (U.S. 2018) (CSLI collection is a Fourth Amendment search for substantial periods 18)
Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applies to the states 19)
Riley v. California, 573 U.S. 373 (U.S. 2014) (digital privacy interests require careful Fourth Amendment limits 20)
Walter v. United States, 447 U.S. 649 (U.S. 1980) (retention and use of overproduced materials can raise constitutional issues 21)
Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (Fourth Amendment applies to government searches and seizures 22)