United States v. Suellentrop, No. 19-1002 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress images and videos retrieved from his cell phone. The court held that the district court correctly determined that investigators and prosecutors were permitted to use the images and video from defendant's phone that an acquaintance viewed on his own initiative. In this case, the Fourth Amendment does not extend to private searches that are neither instigated nor performed on behalf of a government entity; defendant's acquaintance acted entirely on his own when he searched defendant's cell phone; and the agents examining the phone went no further than the private search when they examined the phone. As to the remainder of the materials found on the phone, the court held that the state investigators reasonably understood the state warrant to authorize a search of the phone.
Court Description: [Colloton, Author, with Loken and Kobes, Circuit Judges] Criminal case - Criminal law. The Fourth Amendment does not extend to private searches that are neither instigated nor performed on behalf of a government agency, and, here, the agents examining the phone went no further than the private search when they examined the phone; as as result, they could use the images and videos to obtain a warrant; as to the remainder of the materials found on the phone, the state investigators reasonably believed the state warrant authorized the search of defendant's phone.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.