US v. David Orozco, No. 21-4473 (4th Cir. 2022)

Defendant was paid to drive a car with over $100,000 in drug-tainted cash hidden in a secret dashboard compartment. When police pulled him over, he acted suspiciously: He quickly shut down the GPS application running on his smartphone and struggled to answer where he was going with the money. His odd behavior continued when he arrived at the station: When police found five SD cards wrapped in a $100 bill in Defendant’s shoe, Defendant tried to destroy them by eating them. When police got a warrant to search the phone and SD cards, things went from bad to worse for Defendant—both the phone and the chips contained graphic and heinous child pornography. Defendant contends that the search warrant for the phone and SD cards should not have been issued.
 
The Fourth Circuit affirmed Defendant’s conviction, holding that the district court’s denial of Defendant’s motion to suppress was proper. The court explained that this case presents a model example of a proper investigation under the Fourth Amendment. The officers submitted a comprehensive affidavit with detailed facts showing drug trafficking. The magistrate combined those facts with commonsense inferences and determined that probable cause existed. And when the officers discovered evidence of other crimes, they immediately went back and obtained additional warrants to search and seize those files.