U.S. v. Bishop

In prosecution on firearm charge, Dist. Ct. did not err in denying defendant’s motion to suppress evidence seized after search of defendant’s cell-phone that was made pursuant to search warrant. While defendant argued that description of items to be seized, as contained in warrant, was too general because it allowed officer to search all applications and files in phone and decide which files satisfied description that included all documents or videos depicting crime of criminal recklessness, police could search all files and applications on phone, since incriminating evidence could be contained in any file or folder. Result might be different if police had advance notice of specific files or applications in defendant’s phone where incriminating evidence was located.