02-11-2025, 12:33 AM
Based on the complaint supporting the search warrant, there was probable cause to believe that only two categories of data could possibly be evidence of the crime: photos and videos ( see Doc. 22–2). The complaint did not offer any basis—such as facts learned during the investigation or Detective Lambert's training and expertise—to believe that the calendar, phonebook, contacts, SMS messages, MMS messages,emails, ringtones, audio files, all call logs, installed application data, GPS information, WIFI information, internet history and usage, or system files were connected with Winn's act of public indecency. In fact, the narrative portion of the complaint did not even mention those categories of data. Furthermore, Detective Lambert admitted at the hearing that he had no reason to believe much of that data contained evidence of the crime of public indecency.
United States v. Winn, 79 F. Supp. 3d 904, 919-20 (S.D. Ill. 2015)
United States v. Winn, 79 F. Supp. 3d 904, 919-20 (S.D. Ill. 2015)