United States v. Kevin McCall, 84 F.4th 1317

Kevin McCall allegedly used his cell phone to summon masked gunmen who robbed and shot players at a poker game; victims identified McCall as having frantically used his phone before the attack.
Police obtained a warrant to search McCall’s seized iPhone but the phone was locked; investigators extracted the iCloud account name and last backup time (about 12 hours before the robbery).
Detective Rosen obtained a separate iCloud warrant authorizing Apple to produce essentially the entire account (seven broad categories) with no time limitation; Apple produced ~2.5 months of backups.
Forensic review located photos and videos of McCall (a felon) holding a 9mm pistol; those images led to a federal §922(g)(1) prosecution and conviction.
McCall moved to suppress iCloud-derived evidence, arguing the affidavit lacked probable cause, the warrant was not sufficiently particular, and officer reliance was objectively unreasonable; the district court found the warrant nonparticular but applied the Leon good-faith exception and denied suppression.
On appeal the Eleventh Circuit assumed, without deciding, any Fourth Amendment defects but held the good-faith exception applied and affirmed the denial of suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for iCloud search	Affidavit lacked a sufficient nexus (backup 12 hours earlier) to show evidence would be on iCloud	Reasonable to infer preexisting communications/photos would be in iCloud backups tied to the phone used to arrange the crime	Any probable-cause defects were not so obvious that officers’ reliance was unreasonable; good-faith applies
Particularity / overbreadth of warrant	Warrant was facially deficient because it authorized all account data with no meaningful subject or time limits	Categories were tailored to the investigation and the account contained limited historical data (~2.5 months)	Government conceded overbreadth but warrant was not so facially deficient that reliance was unreasonable; good-faith applies
Objective unreasonableness of reliance	Surrounding circumstances made the warrant obviously invalid and a trained officer should not have relied on it	Officer sought supervisory and prosecutor review; warrant derived from a valid phone warrant and resembled other cloud warrants	Reliance was objectively reasonable given supervisory review, judge approval, and standard practice; good-faith applies

United States v. Leon, 468 U.S. 897 (1984) (establishes the exclusionary rule’s good-faith exception for warrant-based searches)
Davis v. United States, 564 U.S. 229 (2011) (limits exclusionary rule to cases likely to deter future Fourth Amendment violations)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause defined as a practical, commonsense probability standard)
Riley v. California, 573 U.S. 373 (2014) (recognizes the sensitivity and investigative value of cell-phone data)
Messerschmidt v. Millender, 565 U.S. 535 (2012) (good-faith inquiry and when warrant errors are not obvious)
Malley v. Briggs, 475 U.S. 335 (1986) (presumption that magistrate’s probable-cause determination shields officers from liability for mistaken warrants)
United States v. Blake, 868 F.3d 960 (11th Cir. 2017) (affirmed broad social-media search where account was closely linked to criminal activity)
United States v. Morales, 987 F.3d 966 (11th Cir.) (review standard for good-faith exception application)
United States v. Ulbricht, 858 F.3d 71 (2d Cir. 2017) (practical limits on subject-based particularity for digital searches)
United States v. Stowers, 32 F.4th 1054 (11th Cir. 2022) (reliance ordinarily reasonable when a court order appears standard and regular)