United States v. Santiago, 135 F.4th 1235

Alexander William Santiago was convicted of production and possession of child pornography after Oklahoma police seized and searched his iPhone in connection with a missing minor.
The initial search of Santiago’s iPhone was conducted under a state search warrant that was granted based on a broad affidavit without reference to specific crimes.
The warrant resulted in the discovery of evidence leading to a federal warrant and subsequent federal indictment.
Santiago moved to suppress the evidence, arguing both warrants were invalid and evidence was tainted under the Fourth Amendment.
The district court found the state warrant overbroad but applied the good faith exception, allowing the evidence; Santiago was convicted and sentenced.
On appeal, the Tenth Circuit reversed, finding neither warrant supported a good faith exception and ordering evidence suppression.

Issue	Santiago's Argument	Government's Argument	Held
Was the state warrant impermissibly broad?	State warrant lacked particularity, violating Fourth Amendment.	State warrant was not overbroad or good faith exception applies.	Warrant was facially overbroad—violated Fourth Amendment.
Does the good faith exception apply to state warrant?	No reasonable officer could rely on such a plainly broad warrant.	Officers reasonably relied on warrant; exception applies.	Exception does not apply—exclusionary rule triggered.
Is federal warrant valid absent state search results?	Probable cause is lacking if state evidence is excised from affidavit.	Probable cause exists even without state search evidence.	No probable cause; federal affidavit lacked supporting facts.
Should evidence from both searches be suppressed?	All evidence tainted by unconstitutional search must be suppressed.	Good faith exception or alternative lawful basis for federal warrant applies.	Suppression required; convictions and sentences vacated.

Maryland v. Garrison, 480 U.S. 79 (1987) (explained warrant particularity requirement to prevent general searches)
Groh v. Ramirez, 540 U.S. 551 (2004) (no reasonable reliance on patently overbroad warrant)
United States v. Leon, 468 U.S. 897 (1984) (good faith exception for officer reliance on invalid warrants)
Mapp v. Ohio, 367 U.S. 643 (1961) (exclusionary rule applies to states via the Fourteenth Amendment)
United States v. Edwards, 813 F.3d 953 (10th Cir. 2015) (affidavit must show logical connection between alleged crime and evidence sought)