United States v. Chaka Castro
881 F.3d 961
| 6th Cir. | 2018Background
- December 2014: a series of armed home invasions in Dallas; police focused on suspects Chaka Castro and Juan Fernando Olaya.
- Officers seized Olaya’s Samsung Galaxy from a recovered stolen vehicle, conducted a cursory on-site review, then stored the phone; Texas magistrate issued a state warrant describing the phone and authorizing seizure of "physical and digital evidence." The phone was later sent to the FBI for a forensic search under the same state warrant.
- Officers surveilled Castro, obtained consent for a brief search of her phones, and then secured state search warrants for two Castro phones; each warrant referenced probable cause for violations of Texas Penal Code §29.03 (aggravated robbery) but included a broad catch-all phrase authorizing “any other files, deleted or not involved in this or any other unlawful activities.”
- Federal prosecutors charged Castro and Olaya with RICO-related offenses based on evidence recovered from the phones. Both defendants moved to suppress the phone evidence; the district court granted suppression.
- The government appealed. The Sixth Circuit reversed, holding the Castro warrants were sufficiently particular (with severance of the overly broad catch-all) and that the FBI’s later forensic search of Olaya’s phone was permissible under the state warrant (and in the alternative supported by the Leon good-faith exception).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Particularity of Castro warrants (use of phrase "a crime" and catch-all) | "A crime" is unparticularized and catch-all phrase permits unlimited search; warrants violate Fourth Amendment | Warrants identified aggravated robbery and context limits "a crime" to those offenses; catch-all severable | Warrant sufficiently particular when read in context; sever the overly broad catch-all; admit evidence obtained under valid portions |
| Permissibility of federal forensic search of Olaya's phone months after state cursory search | Federal agents exceeded state-warrant scope by conducting a full forensic search later and seeking additional crimes/ interstate evidence | Federal agents acted under the state warrant searching for the same evidence; later forensic search is allowed if within original probable cause and device remained secured; alternatively good-faith | Forensic search lawful: it did not exceed the state warrant's probable-cause scope; even if error, Leon good-faith exception applies |
Key Cases Cited
- Andresen v. Maryland, 427 U.S. 463 (contextual reading can limit catch-all language to the crime described earlier)
- United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule)
- United States v. Garcia, 496 F.3d 495 (6th Cir.) (federal officers may assist state searches when seeking same evidence)
- United States v. Evers, 669 F.3d 645 (6th Cir.) (later, more detailed search permissible if within original probable cause and device secured)
- United States v. Keszthelyi, 308 F.3d 557 (6th Cir.) (rule on repeat searches and "reasonable continuation")
- United States v. Willoughby, 742 F.3d 229 (6th Cir.) (warrant language can serve as global modifier limiting scope)
- Groh v. Ramirez, 540 U.S. 551 (warrant defects may render reliance unreasonable)
- Davis v. United States, 564 U.S. 229 (standard for suppression when officers act deliberately or recklessly)