United States v. Singleton
Brief Details
- Case No.: 26-1087
- Brief Filed: August 18, 2026
- Jurisdiction: 7th Circuit Court of Appeals
Key Topics in the Brief
Briefs
Argument(s)
The Fourth Amendment’s particularity requirement prohibits free-ranging searches and is especially important for cell phones and other digital devices containing vast quantities of sensitive personal information. The warrants authorizing searches of Singleton’s three cell phones were facially deficient because they permitted searches of every file on the phones without temporal or subject-matter limitations, despite law enforcement possessing information that could readily have narrowed the searches. The good-faith exception does not apply to such plainly unparticularized warrants. The district court further erred by treating qualified immunity under 42 U.S.C. § 1983 and the Fourth Amendment good-faith exception as effectively interchangeable. Although both doctrines employ concepts of objective reasonableness, they developed for different purposes and apply through different standards; qualified immunity's protection of officers from civil liability is more forgiving than the good-faith inquiry governing suppression of evidence. Extending the good-faith exception based on qualified-immunity precedent would weaken the Fourth Amendment’s protection against general digital searches. The evidence obtained from Singleton’s phones should therefore have been suppressed and the case remanded for further proceedings.
Author(s)
Kimball R. Anderson, Patrick G. Simonaitis, Sarah Barritt Conner, and Matthew W. Woodruff, Winston Taylor LLP, Chicago, IL
