U.S. v. Burgard

In prosecution on receipt of child pornography charge, Dist. Ct. did not err in denying defendant's motion to suppress pictures found in defendant's cell phone that had been initially seized pursuant to tip by informant, but not searched until 6 days later when police had obtained warrant to search cell phone. Ct. found that 6-day delay in securing warrant was not unreasonable for 4th Amendment purposes where police had probable cause to seize cell phone, and where officer took various steps to draft warrant application and consult Assistant U.S. Attorney. Ct., though, further noted that good-faith exception would normally not apply in cases where unreasonable delay had occurred in obtaining search warrant.