State v. Correa

Citations

• 353 Conn. 338

Syllabus

Convicted of murder with special circumstances, home invasion, arson in the second degree, and robbery in the first degree in connection with the planned invasion and robbery of the home of the murder victims, M, K and J, the defendant appealed to this court. Shortly before the crimes occurred, the defendant texted with M, K and J's son, in order to plan a robbery whereby M would help the defendant steal K's gun safe and guns, which were located in the family home, in exchange for drugs and money. When the defendant and his sister, R, arrived in the area of the victims' home, they met with M and killed him in a nearby wooded area. Subsequently, the defendant and R entered the victims' home, where the defendant killed K and J. The defendant and R remained in the home and stole various items and then set the home on fire. Prior to the defendant's arrest, the police interviewed the defendant, immediately after which they seized his cell phone without a warrant. The police later obtained a warrant to search and seize ''all data'' from the defendant's cell phone, ''including, but not limited to, all call logs . . . [t]ext messaging, telephone numbers stored, address book, calendar, email, video files, and graphic files.'' The warrant did not identify any temporal parameters within which to limit the search. An extrac- tion of the data from the cell phone yielded, among other information, global positioning system (GPS) data, text message communications the defendant 353 Conn. 338 SEPTEMBER, 2025 339 State v. Correa had with, among others, R and T, the defendant's girlfriend, and certain photographs and Internet searches suggesting that the defendant had researched how to break into a gun safe. Before trial, the defendant moved to suppress all evidence obtained from his cell phone, contending that the police had illegally seized his cell phone and that the warrant was unconstitutional because it permitted the police to search and seize ''all data'' from his cell phone wit