United States v. Royce Jobe, 933 F.3d 1074

DHS received a tip that Jobe was running a large marijuana grow at his Van Nuys residence; agents corroborated factors like increased power use, PVC piping, planters, cooling fans, and late-night traffic.
Special Agent Paul Cotcher prepared an affidavit describing the tip, observations, Jobe’s prior convictions, and a business named “420 Boutique.” A state judge issued a search warrant authorizing seizure of items including "hard drives."
On Nov. 22, officers executed the state warrant and seized drugs, a pistol, the laptop, and other devices; the laptop was not searched that day.
Cotcher contacted the USAO about federal prosecution, investigated further for ~10 days, then, after USAO agreed to prosecute, prepared a federal warrant affidavit; agents searched the laptop 20 days after seizure.
Laptop evidence led to federal charges (identity theft, unauthorized access, mail fraud, felon-in-possession). The district court suppressed laptop evidence as a product of an unreasonable delay in obtaining the federal warrant; the government appealed and the Ninth Circuit reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of seizure under state warrant	State warrant did not mention computers; seizure of laptop lacked probable cause.	Affidavit supported seizing items "tending to establish and document sales of marijuana," reasonably including digital devices.	Seizure was supported by objectively reasonable reliance on the state warrant; good-faith exception applies.
20-day delay before federal search warrant	Delay between seizure and federal warrant was unreasonable and warrants suppression.	Delay was not deliberate, reckless, or grossly negligent; Cotcher acted reasonably (consulted USAO, investigated, drafted affidavit).	Delay did not warrant exclusion; suppression not appropriate.
Applicability of exclusionary rule for delay	Exclusion should deter unreasonable delays that infringe Fourth Amendment rights.	Exclusion applies only where deterrence justifies social costs; here police conduct was not sufficiently culpable.	Exclusionary rule not triggered because conduct lacked the culpability (deliberate/reckless/gross negligence) and was an isolated, reasonable delay.
Good-faith reliance on warrants	Subsequent federal warrant can't cure initial unlawful seizure.	Good-faith reliance on a magistrate-authorized state warrant and a valid federal warrant supports admission.	Officers reasonably relied on warrants; no allegations of misleading omissions; good-faith reliance supports reversal of suppression.

Herring v. United States, 555 U.S. 135 (exclusionary rule targets deliberate/reckless/grossly negligent or systemic negligence)
United States v. Leon, 468 U.S. 897 (good-faith reliance on warrant limits exclusionary rule)
United States v. Cha, 597 F.3d 995 (9th Cir. 2010) (delay-related suppression factors; officer culpability guideposts)
United States v. Calandra, 414 U.S. 338 (exclusionary rule’s deterrent purpose)
Davis v. United States, 564 U.S. 229 (weigh deterrent value against social costs of exclusion)
Illinois v. Gates, 462 U.S. 213 (probable cause standard for warrants)
United States v. Sullivan, 797 F.3d 623 (9th Cir. 2015) (21-day delay reasonable where seizure was lawful via consent)
United States v. Dass, 849 F.2d 414 (9th Cir. 1988) (delay in obtaining warrants for mass seizures; distinguished here)