State v. Tyler, 291 Neb. 920

Shooting outside Halo Ultra Lounge in Omaha; victim Delayno Wright died of gunshot wound.
Investigators linked Avery Tyler to the crime via an eyewitness ID, photos, and crime-scene evidence.
Four search warrants were issued for Tyler's car, grandparents' residence, mother's residence, and girlfriend's residence; warrants sought firearms, evidentiary items, and venue items.
Cell phone seized from Tyler’s car; gunlock seized from grandparents’ residence; Tyler signed a consent form to search the cell phone contents.
District court denied suppression motions; trial admitted the challenged evidence; Tyler was convicted of murder and related firearm offense.
On appeal, Tyler challenges the lawfulness of seizure, consent, and warrant particularity; the court affirms the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the cell phone was seized unlawfully.	Tyler—cell phone seized during unlawful arrest/search.	State—cell phone obtained under warrant-served search; not from arrest.	Cell phone obtained under warrant, not from arrest; not suppressed.
Whether Tyler voluntarily consented to the cell phone search.	Consent coerced or not voluntary.	Consent given voluntarily under totality of circumstances.	Consent voluntarily given; denial of suppression upheld.
Whether warrants were sufficiently particular.	Warrants too broad; impermissibly open-ended.	Warrants sufficiently particular; severable portions valid.	Warrant for firearm search sufficiently particular; severability applies; good-faith exception supports admission.
Whether the good-faith exception applies to the warrant execution.	Invalid portions taint all evidence.	Good faith reliance after mixed validity; not all evidence suppressed.	Good faith exception applies; suppression not required.
Whether the gunlock and cell phone evidence should be excluded due to warrant issues.	Evidence seized under possibly invalid portions.	Particular portion valid; severable; good faith supports admission.	Gunlock seizure upheld under valid portion; not suppressed.

State v. LeBron, 217 Neb. 452, 349 N.W.2d 918 (Neb. 1984) (severability of warrant provisions and partial suppression allowed)
State v. Hedgcock, 289 Neb. 271, 854 N.W.2d 616 (Neb. 2014) (consent and good-faith considerations in search)
State v. Henderson, 289 Neb. 271, 854 N.W.2d 616 (Neb. 2014) (good-faith exception and particularity analysis)
State v. Osborn, 250 Neb. 57, 547 N.W.2d 139 (Neb. 1996) (implicit findings and review of suppression rulings)
United States v. Fitzgerald, 724 F.2d 633 (8th Cir. 1983) (multifaceted approach to warrant validity and severability)