STATE v. WALLACE, 442 P.3d 175

Brittney Jo Wallace was charged with two counts of Enabling Child Abuse and one count of Child Neglect after two of her sons sustained serious, atypical injuries.
Medical personnel told police the injuries were inconsistent with the history provided by Wallace and her boyfriend.
Wallace told the detective she had photographed the boys' injuries and sent the photos to her mother; the mother corroborated this.
On May 13, 2016, a detective seized Wallace's cell phone (located in Tulsa County) and accessed settings to forward calls and place the phone in airplane mode to prevent remote wiping; no passcode was reported.
A search warrant for the phone was later obtained; the trial court suppressed all evidence from the phone, ruling the initial seizure and the subsequent warrant were invalid.
The State appealed; the Oklahoma Court of Criminal Appeals reversed, holding the initial seizure and accessing of the phone were reasonable and that the district court improperly evaluated the warrant without requiring a proper challenge or considering the good-faith exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless seizure and limited access to Wallace's cell phone were lawful	State: Detective had probable cause and exigent need to seize/secure the phone to prevent deletion of evidence	Wallace: Initial seizure and accessing of phone violated Fourth Amendment	Court held seizure and limited accessing (call forwarding, airplane mode) were reasonable under totality of circumstances and Riley/Thomas exceptions; suppression reversed
Whether the later search warrant was invalid (overbroad, unsupported, or based on false statements)	State: District court failed to require Wallace to specifically challenge affidavit/warrant, gave insufficient deference to magistrate, and did not consider good-faith exception	Wallace: District court found warrant insufficiently particular and possibly containing false/mistaken representations	Court held district court abused its discretion by ruling on warrant validity without the required specific challenge/evidence and without considering magistrate deference or good-faith exception; remanded for further proceedings

Riley v. California, 573 U.S. 373 (police generally need a warrant to search cell‑phone data; may secure device to prevent remote wiping)
Segura v. United States, 468 U.S. 796 (societal interest in preserving evidence can justify temporary seizure)
United States v. Leon, 468 U.S. 897 (good‑faith exception to exclusionary rule for reliance on defective warrants)
Franks v. Delaware, 438 U.S. 154 (requirements for alleging falsehoods in warrant affidavits to obtain a hearing)
Moore v. State, 788 P.2d 387 (warrant specificity; items to be seized must be particularized)
State v. Thomas, 334 P.3d 941 (Oklahoma case applying Riley principles to cell phones)