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USAv.Alejandro Barron-Soto, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.13-14731
DecidedApril 26, 2016
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalCriminal ProcedureFourth AmendmentSearch and SeizureDigital EvidenceMotion to SuppressSufficiency of the EvidenceReversal
Case Summary

Alejandro Barron-Soto and a codefendant appealed federal convictions involving drug trafficking, challenging the denial of suppression motions and the sufficiency of the evidence. The Eleventh Circuit considered the effect of the Supreme Court’s decision concerning searches of cell phones and reviewed a limited remand on whether officers would have sought a warrant independently of information obtained from a forensic examination. The court held that the evidence obtained from the defendants’ phones was admissible under the independent-source doctrine because the government established that it would have pursued the warrant without relying on the challenged forensic scan. The court also held that the trial evidence permitted a reasonable factfinder to find the defendants guilty beyond a reasonable doubt. It therefore rejected the suppression and judgment-of-acquittal challenges and affirmed both convictions. The published opinion addressed the interaction between modern digital searches, warrant practice, and independent-source analysis.

Opinion

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USA v. Alejandro Barron-Soto, et al. — The Atlanta Gleaner