United States v. Belmonte Cardozo

Brief of the American Civil Liberties Union, Electronic Frontier Foundation, National Association of Criminal Defense Lawyers, ACLU of Maryland, ACLU of North Carolina, ACLU of South Carolina, and ACLU of Virginia as Amici Curiae in Support of Defendant–Appellant and Reversal

Brief filed: 10/28/2025

Documents

United States v. Belmonte Cardozo

4th Circuit Court of Appeals; Case No. 25-4239

Prior Decision

Appeal to the Fourth Circuit from the United States District Court for the Eastern District of Virginia, Alexandria Division (No. 1:24-cr-00125) court’s orders entering judgment and conviction for Mr. Belmonte Cardozo (April 15, 2025).

Argument(s)

Customs and Border Protection (“CBP”) agents conducted a secondary inspection of Mr. Belmonte Cardozo at Dulles Airport upon his return to the United States from a trip to Bolivia. While searching his belongings, CBP agents ordered Mr. Belmonte Cardozo to provide the passcodes to two iPhones in his possession upon the authority of a CBP “tear sheet” stating that travelers are “obligated” to unlock their devices.

NACDL and co-amici’s brief argues that there should be a warrant requirement for device searches at the border. This case jurisprudentially follows United States v. Kolsuz, 890 F.3d 133 (4th Cir. 2018) in which the Fourth Circuit held that that a forensic search of a device at the border must require individualized suspicion. The Court did not address the standard for manual device searches at this border, as occurred in Mr. Belmonte Cardozo’s case. Amici argue that a warrant should be required for all forms of device searches at the border, but at minimum, the individualized suspicion standard should be extended to manual searches as well following Kolsuz.

Author(s)

Michael Price, NACDL Fourth Amendment Center; Elizabeth Franklin-Best, NACDL Amicus Committee Vice-Chair; Esha Bhandari, American Civil Liberties Union; Nathan Freed Wessler, American Civil Liberties Union; Sophia Cope, Electronic Frontier Foundation; Eden B. Heilman, ACLU of Virginia; David Rocah, ACLU of Maryland; Kristi L. Graunke, ACLU of North Carolina; Allen Chaney, ACLU of South Carolina

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