United States v. Wallace, 1:24-cr-00411

Defendant Anthony Wallace moved to suppress evidence obtained from his cellphone following execution of a search warrant (April 5, 2024) in connection with alleged child exploitation and trafficking crimes.
The search warrant was issued by Magistrate Judge Tarnofsky, supported by a detailed affidavit from Detective Thorpe, outlining Wallace's alleged use of the phone to facilitate and document serious offenses, including sex trafficking of a minor, kidnapping, and child pornography.
The warrant described the subject device with specificity (model, appearance, photos) and set forth twelve specific categories of electronic evidence to be seized relating to the alleged crimes.
Wallace argued the warrant was constitutionally deficient due to lack of particularity and overbreadth, as well as absence of a temporal limitation on the data to be searched.
The government opposed suppression, arguing both particularity and breadth requirements were met, and that officers executed the warrant in good-faith reliance on the magistrate's authorization.
The Court denied Wallace's motion to suppress, finding the warrant sufficiently particular and not overbroad, and held the good-faith exception would apply even if there were constitutional defects.

Issue	Wallace's Argument	Government's Argument	Held
Particularity	The warrant lacked meaningful detail and guidance, failing to describe suspected crimes or limit search scope.	The warrant identified specific offenses, detailed the device, and listed categories of evidence tied to the offenses.	Sufficiently particular; statutory references and evidence categories met the requirement.
Overbreadth	The warrant permitted seizure of overly broad categories of ESI without a proper nexus to crimes charged.	Limitation to evidence of specified offenses, using twelve subcategories, was sufficient and standard.	Not overbroad; evidence categories tied to probable cause and relevant offenses.
Time Limitation	Lack of date restrictions allowed a review of an entire communications history, rendering the warrant invalid.	No binding precedent requires temporal limits for warrants; lack of such limits is not fatal.	Court did not decide definitively; good-faith reliance applies even if a defect existed.
Good Faith Exception	The warrant was so facially deficient that officers’ reliance was unreasonable.	Officers relied on a magistrate's authorization with explicit offense and evidence categories.	Good faith exception applies; suppression not warranted even if there had been a defect.

United States v. Galpin, 720 F.3d 436 (2d Cir. 2013) (sets out particularity requirements and heightened concern for ESI searches)
United States v. Ulbricht, 858 F.3d 71 (2d Cir. 2017) (warrants listing crimes charged satisfy particularity; digital search context)
United States v. Leon, 468 U.S. 897 (1984) (establishes good-faith exception to exclusionary rule)
Payton v. New York, 445 U.S. 573 (1980) (origin of Fourth Amendment's stance against general warrants)
Steagald v. United States, 451 U.S. 204 (1981) (general warrants allow officer discretion forbidden by Fourth Amendment)
Herring v. United States, 555 U.S. 135 (2009) (suppression is a last resort; exclusionary rule)
Messerschmidt v. Millender, 565 U.S. 535 (2012) (presumption of objective good faith when magistrate issues warrant)