USA v. Hutchings, No. 22-3069 (D.C. Cir. 2024)
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The case revolves around James Hutchings, Jr., who was convicted of conspiracy to unlawfully traffic and transport firearms. The conviction was based on evidence obtained from Hutchings's iPhone, which was seized during the arrest of suspected firearms and narcotics trafficker Linwood Thorne. The phone was found in Thorne's apartment, and a separate warrant was obtained to search the phone based on its association with Thorne. It was only after the search began that the agents realized the phone belonged to Hutchings.
The case was first heard in the United States District Court for the District of Columbia, where Hutchings moved to suppress the evidence from his phone, arguing that the search was unsupported by the warrant because the probable cause finding depended on the phone's association with Thorne. The district court denied Hutchings's motion, stating that the phone was indeed associated with Thorne, regardless of its ownership. Hutchings was found guilty and sentenced to 60 months in prison followed by three years of supervised release.
The case was then appealed to the United States Court of Appeals for the District of Columbia Circuit. Hutchings argued that the officers reviewing the report were required to discontinue their search after seeing the notation on its first page that the phone was "James's iPhone." The court disagreed, stating that the validity of the warrant did not depend on who owned the phones, but on their association with Thorne. The court affirmed the judgment of the district court, stating that the label "James's iPhone" did not contradict the facts that supported the warrant application.
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