James Crocker stopped near an interstate crash and used his iPhone to photograph the scene after other bystanders had done the same. A deputy sheriff took the phone without a warrant, said the images were evidence, and refused to return it unless Crocker went to a weigh station. Crocker sued under Section 1983, alleging that the seizure violated the Fourth Amendment. The district court denied the deputy’s motion for summary judgment on that claim, and the Eleventh Circuit affirmed. The court assumed that the photographs might have been evidence but held that no objectively reasonable officer could have believed their destruction was imminent. Crocker was merely a bystander, had not been implicated in the crash, and had given no indication that he would delete the images before a warrant could be obtained. The court further held that the general constitutional rule against warrantless seizures of personal property was clearly established in 2012, so the deputy was not entitled to qualified immunity. The seizure claim therefore remained for trial.