Supreme Court of Missouri / Aug 31, 2021
State of Missouri, Appellant, vs. James Christopher Bales, Respondent.
The State appealed the circuit court's order suppressing a cell phone and its electronic data seized from James Bales. The circuit court found the search warrant lacked particularity and was facially deficient, and that the good faith exception did not apply. The Missouri Supreme Court affirmed the suppression, holding that the seizure of the cell phone at the sheriff's office was outside the scope of the warrant, which specified a search at a particular address. The Court further held that the good faith exception to the exclusionary rule did not apply because it was not objectively reasonable for the officer to execute the warrant outside its authorized scope.