Taylor v. State, 260 A.3d 602

Diamonte Taylor ("D‑Nice") was charged after a May 2016 series of gang‑related shootings and a murder (Brandon Wingo); investigators linked Taylor by witness ID, ballistics, and accomplice testimony.
Taylor was arrested June 1, 2016; officers seized multiple smartphones from him and from the vehicle.
A Justice of the Peace issued a warrant authorizing seizure and forensic examination of “any/all data” on Taylor’s phones (broad categories listed) with no explicit time limitation.
Forensic extraction of one phone produced thousands of pages/files spanning roughly 2005–2016; the State introduced 95 pages and images at trial, including texts and photos implicating Taylor.
Superior Court denied Taylor’s suppression motion; a jury convicted him of first‑degree murder and other violent felonies; Taylor appealed arguing the warrant was an unconstitutional general warrant and the error was not harmless.
The Delaware Supreme Court held the warrant was a general warrant (violating the Fourth Amendment, Delaware Constitution, and state statute), suppressed the phone evidence should have been granted, and reversed and remanded for a new trial because the error was not harmless.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Whether the smartphone search warrant was an unconstitutional general warrant lacking particularity	Warrant was sufficiently tied to the investigation because the affidavit recited relevant incident dates and identified the phones; any vagueness was cured by limiting evidence to relevant timeframe	Warrant authorized "any/all data" with "including but not limited to" language and no time limit, permitting a top‑to‑bottom exploratory search	Warrant was a general warrant; lacked required particularity and temporal limitation; invalid under Fourth Amendment, Delaware Const., and 11 Del. C. §2306; suppression required.
Whether admission of the phone evidence was harmless error	Other non‑phone evidence (witnesses, ballistics, social media) was overwhelming, so any error was harmless	Phone evidence was central: texts, photos, and admissions tied Taylor to shootings and murder; without it the verdict cannot be assured	Error was not harmless beyond a reasonable doubt; phone evidence materially contributed to convictions; reversal and new trial required.

Riley v. California, 573 U.S. 373 (smartphones implicate heightened privacy; searches require careful particularity)
Buckham v. State, 185 A.3d 1 (Del. 2018) (warrant authorizing search of any phone data and no time frame is a general warrant)
Wheeler v. State, 135 A.3d 282 (Del.) (electronic device warrants must be no broader than probable cause and specify time/place when reasonably possible)
Coolidge v. New Hampshire, 403 U.S. 443 (general warrants permit prohibited exploratory rummaging)
United States v. Yusuf, 461 F.3d 374 (3d Cir.) (distinction between overly broad warrants and general warrants; remedy is suppression for general warrants)
James v. Illinois, 493 U.S. 307 (erroneously admitted evidence must be shown harmless beyond a reasonable doubt when constitutional rights implicated)