In Pohland v. State, the court of appeals held the general search of an individual’s laptop to be unconstitutional when conducted under a warrant authorizing the search of another individual’s digital records related to that second individual’s suspected crimes. Alaska state troopers investigating McRoberts obtained a search warrant authorizing search and seizure of all digital storage devices in McRoberts’ house for review of digital financial records to the extent that the records related to her suspected crimes. Pohland, a state employee and friend of McRoberts, rented a suite within McRobert’s home. During the search of McRoberts’ house, Pohland’s laptop was seized and searched, leading to the state to charge her with official misconduct. The district court found the state troopers had probable cause to believe that McRoberts, as Pohland’s close friend, might have concealed evidence within the latter’s living area. On appeal, the state argued the search of Pohland’s laptop to be proper as McRoberts’ might have hidden evidence of her suspected crimes on the laptop. The court of appeals held that the fact that Pohland’s laptop was in a rented space within McRoberts’ house and Pohland was McRoberts’ friend did not merit the inference that there was evidence of the suspected crimes on the laptop, nor did it allow for a search unrestricted to financial records that may have been hidden on the computer. The court of appeals reversed, holding the general search of an individual’s laptop to be unconstitutional when conducted under a warrant authorizing the search of another individual’s digital records related to that second individual’s suspected crimes.
 436 P.3d 1093 (Alaska Ct. App. 2019).