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Macasaet v. State

CRIMINAL PROCEDURE
Court of Appeals of Alaska (2025)
Mike Galane

In Macasaet v. State, 566 P.3d 287 (Alaska Ct. App. 2025), the Court of Appeals of Alaska held that warrants authorizing a search of a cell phone’s “app data” are too broad and therefore violate the Fourth Amendment’s particularity requirement, but a warrant authorizing a search for “text messages” includes messages sent via social media applications. (Id. at 298–99). A trial court found Macasaet guilty of first-degree murder. (Id. at 291). The police obtained a search warrant for “app data” and “text messages” on Macasaet’s phone. (Id. at 297). Under the “app data” provision of the warrant, officers reviewed messages that Macasaet sent via Facebook Messenger. (Id. at 296). Macasaet appeals that the trial court should have suppressed evidence of his communications via Facebook Messenger. (Id. at 297). Macasaet argues that the warrant illegally authorized a search for “app data” that was insufficiently particular to view messages sent via social media applications. (Id.). Because smartphones contain massive amounts of personal data, a warrant to search a cell phone’s “app data” must sufficiently and precisely define the data that the police want. (Id. at 299). If a warrant for “app data” doesn’t specify the data sought by police, then the warrant illegally authorizes a general exploratory search in violation of the Fourth Amendment. (Id.). However, a warrant to review “text messages” allows law enforcement to view messages sent via social media applications because the common understanding of the phrase “text messages” includes texts sent through messaging applications. (Id.). Accordingly, the court of appeals held that warrants authorizing a search of a cell phone’s “app data” are too broad and therefore violate the Fourth Amendment’s particularity requirement. However, a warrant authorizing a search for “text messages” includes messages sent via social media applications. (Id. at 298–99). The court of appeals affirmed Macasaet’s conviction. (Id. at 312).

Macasaet v. State

CRIMINAL PROCEDURE
Court of Appeals of Alaska (2025)
Mike Galane

In Macasaet v. State, 566 P.3d 287 (Alaska Ct. App. 2025), the Court of Appeals of Alaska held that warrants authorizing a search of a cell phone’s “app data” are too broad and therefore violate the Fourth Amendment’s particularity requirement, but a warrant authorizing a search for “text messages” includes messages sent via social media applications. (Id. at 298–99). A trial court found Macasaet guilty of first-degree murder. (Id. at 291). The police obtained a search warrant for “app data” and “text messages” on Macasaet’s phone. (Id. at 297). Under the “app data” provision of the warrant, officers reviewed messages that Macasaet sent via Facebook Messenger. (Id. at 296). Macasaet appeals that the trial court should have suppressed evidence of his communications via Facebook Messenger. (Id. at 297). Macasaet argues that the warrant illegally authorized a search for “app data” that was insufficiently particular to view messages sent via social media applications. (Id.). Because smartphones contain massive amounts of personal data, a warrant to search a cell phone’s “app data” must sufficiently and precisely define the data that the police want. (Id. at 299). If a warrant for “app data” doesn’t specify the data sought by police, then the warrant illegally authorizes a general exploratory search in violation of the Fourth Amendment. (Id.). However, a warrant to review “text messages” allows law enforcement to view messages sent via social media applications because the common understanding of the phrase “text messages” includes texts sent through messaging applications. (Id.). Accordingly, the court of appeals held that warrants authorizing a search of a cell phone’s “app data” are too broad and therefore violate the Fourth Amendment’s particularity requirement. However, a warrant authorizing a search for “text messages” includes messages sent via social media applications. (Id. at 298–99). The court of appeals affirmed Macasaet’s conviction. (Id. at 312).