State v. Joseph McElroy

CourtCourt of Appeals of Georgia
DecidedJune 25, 2024
DocketA24A0420
StatusPublished

This text of State v. Joseph McElroy (State v. Joseph McElroy) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Joseph McElroy, (Ga. Ct. App. 2024).

Opinion

FIRST DIVISION BARNES, P. J., GOBEIL and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 25, 2024

In the Court of Appeals of Georgia A24A0420. THE STATE v. MCELROY.

PIPKIN, Judge.

The State appeals from the grant of Joseph McElroy’s pre-trial motion to

suppress.1 For the reasons that follow, we reverse in part, vacate in part, and remand

with direction.

1. In reviewing the trial court’s grant of the motion to suppress, “we apply the

well-established principles that the trial court’s findings as to disputed facts will be

upheld unless clearly erroneous and the trial court’s application of the law to

undisputed facts is subject to de novo review.” (Citation and punctuation omitted.)

1 McElroy is charged with aggravated child molestation, aggravated sodomy, incest, enticing a child for indecent purposes, and two counts of sexual exploitation of children. State v. Palmer, 285 Ga. 75, 78 (673 SE2d 237) (2009). The record here shows that, on

June 20, 2021, law enforcement officers “received a call from parole regarding an

incident that occurred at []McElroy’s parents’ house,” where McElroy resided. Upon

their arrival, the lead detective spoke with A. M., McElroy’s 11-year-old nephew. A.

M. stated that, around 4 o’clock that morning, McElroy entered the room where A.

M. was sleeping and told the child that McElroy “had a way to make him a lot of

money.” After this, McElroy led A. M. into another bedroom and performed oral sex

on the child while recording the incident with an iPhone.

At some point thereafter, the lead detective called another officer (hereinafter

“the swearing officer”) asking for assistance in obtaining a warrant to seize and search

McElroy’s cell phone. While the lead detective remained on the scene, the swearing

officer applied for a search warrant. In an affidavit supporting the warrant application,

the swearing officer included information that had been relayed to him, including the

minor child’s outcry and the fact that the alleged act was recorded by McElroy on his

cell phone. The swearing officer requested to seize McElroy’s iPhone and search the

phone for “[d]ata contained within [the iPhone] to include images, video, and

log/data files pertaining to [the] creation and storage of images and video,” noting

2 that “devices such as the Apple iPhones are capable of creating and storing both

digital images and video recordings.” The swearing officer further stated that, “[i]n

addition to the actual images and video[,] Affiant knows other files of interest related

to the creation and storage of video and images may exist in the form of cache files,

database entries, and other log type files created during normal operation of the Apple

iPhone.” Finally, the application noted that the cell phone was “used in the

commission of the crime(s) herein described,” was “contraband, the possession of

which is unlawful,” and was “tangible evidence of the commission of the crime(s) set

forth above.”

The swearing officer also provided oral testimony to the magistrate judge in

support of the warrant application.2 The officer’s testimony was recorded, and the

recording was tendered as an exhibit at the suppression hearing; the recording shows

that the magistrate judge, after reviewing the warrant application, asked the swearing

officer for more information regarding the requested search. The swearing officer

informed the judge that the alleged criminal act was filmed that morning at

2 See Simpson v. State, 159 Ga. App. 235, 236 (1) (283 SE2d 91) (1981) (“A magistrate may consider oral testimony as well as the affidavit in issuing [a] warrant.”). 3 approximately 4 o’clock on McElroy’s iPhone, and, further, that he was seeking the

warrant “to retrieve the phone and therefore the data on it - the video - present on the

device.” The swearing officer also testified that McElroy’s mother had identified the

specific cell phone that belonged to McElroy. After hearing this testimony, the

magistrate judge determined that probable cause existed, signed the search warrant,

and authorized the seizure and search of McElroy’s iPhone.

McElroy challenged the validity of the search and seizure of his cell phone in

a pretrial motion to suppress. At a hearing on the motion, the State called the two law

enforcement officers involved in obtaining the warrant for the phone and the

subsequent search of the same. Regarding the seizure of the phone, the lead detective

testified that he did not seize the phone until he had the warrant, and he denied

threatening anyone in order to obtain the cell phone. The swearing officer testified

that he conducted the forensic search of McElroy’s cell phone. He explained that he

delivered the signed warrant to the McElroy residence, after which he collected the

cell phone and returned to the lab at the sheriff’s office where he searched the phone

for the relevant video. McElroy’s mother, Pamela Ramsey, testified at the hearing that

4 the lead detective threatened to “destroy [her] home” if she did not hand over

McElroy’s phone, and that she turned over the cell phone because she was scared.

The trial court implicitly credited Ramsey’s testimony and granted the motion

to suppress, finding, in relevant part, that “law enforcement seized [McElroy’s] cell

phone without a warrant, valid consent, or any exception to the warrant requirement.”

The trial court further determined that the search warrant “failed to limit the

authorities’ search of [McElroy’s] private property to the date and time of the alleged

crime,” authorizing a general search of McElroy’s phone. On appeal, the State

contends that this was error, arguing that the search warrant did not authorize a

general search. The State also argues, in part, that the evidence from the seizure and

search of McElroy’s phone should not have been excluded pursuant to the

independent source and inevitable discovery doctrines. We address these arguments

in turn.

2. The State contends that the trial court erred by determining that the search

warrant at issue authorized an impermissible general search. We agree. As recently

explained by the Georgia Supreme Court,

[t]he Fourth Amendment to the United States Constitution requires that a search warrant particularly describe the article or articles sought. In

5 addition to requiring that officers have enough guidance to locate and seize only those items the warrant authorizes them to seize, this particularity requirement also prevents general searches—that general, exploratory rummaging in a person’s belongings by the government that has been rejected since the founding as a violation of fundamental rights. The particularity requirement is applied with a practical margin of flexibility, depending on the type of property to be seized, and a description of property will be acceptable if it is as specific as the circumstances and nature of activity under investigation permit. The uniformly applied rule is that a search conducted pursuant to a warrant that fails to conform to the particularity requirement of the Fourth Amendment is unconstitutional.

(Citations and punctuation omitted.) State v. Wilson, 315 Ga. 613, 614-615 (884 SE2d

298) (2023). McElroy argues that the trial court properly concluded that the warrant

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Related

State v. Palmer
673 S.E.2d 237 (Supreme Court of Georgia, 2009)
Teal v. State
647 S.E.2d 15 (Supreme Court of Georgia, 2007)
Simpson v. State
283 S.E.2d 91 (Court of Appeals of Georgia, 1981)
State v. Wilson
884 S.E.2d 298 (Supreme Court of Georgia, 2023)

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State v. Joseph McElroy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-joseph-mcelroy-gactapp-2024.