## Facts

- Police investigated Christopher Wheeler for suspected witness tampering after he contacted two brothers who confronted him about alleged past sexual abuse.
- Police obtained two warrants authorizing searches for witness-tampering evidence at Wheeler’s home and office.
- The warrants broadly authorized seizure and search of essentially all of Wheeler’s electronic devices and records, without meaningful limiting features.
- Officers seized 19 electronic devices and digital media; they found no evidence of witness tampering on those devices.
- During a cursory search of an iMac found in a closet, officers discovered child-pornography images stored in a newsgroup cache.
- The warrant applications used boilerplate language copied from a child-pornography template despite being justified as witness-tampering warrants.
- Wheeler was charged with 25 counts of dealing in child pornography, each tied to one image found on the iMac, and was sentenced to 50 years of incarceration.
- The State admitted it had no proof Wheeler ever viewed the cached images, which were automatically stored without human intervention.
- The trial court denied Wheeler’s motion to suppress the digital evidence and denied his motion for judgment of acquittal; a jury convicted him on all counts.

## Issues

1. Whether the search warrants, though nominally directed at witness tampering, lacked sufficient particularity and operated as unconstitutional general warrants under the Fourth Amendment and the Delaware Constitution.
2. Whether the evidence was sufficient to prove the knowledge element for dealing in child pornography when the images were automatically cached and the State could not show Wheeler viewed them.

## Decision

- The Delaware Supreme Court reversed.
- The court held the warrants were unconstitutionally broad general warrants because they effectively authorized a search of Wheeler’s “entire digital universe” with no meaningful limitations.
- The court ordered suppression of the child-pornography evidence obtained from the iMac.
- Because the convictions depended on suppressed evidence, the court reversed the judgments of conviction.

## Legal Principles

- The Fourth Amendment and Delaware’s counterpart require particularity sufficient to prevent general, exploratory rummaging through a person’s belongings, including digital data.
- A warrant authorizing seizure and search of virtually all electronic devices and records, without temporal or subject-matter constraints tied to the suspected crime, violates the particularity requirement and is invalid as a general warrant.
- Boilerplate warrant language inconsistent with the stated target offense can reinforce a finding that the warrant lacks objective particularity.
- When unlawfully obtained evidence is central to the prosecution’s case, suppression requires reversal of convictions dependent on that evidence.

## Conclusion

The Delaware Supreme Court held that sweeping digital search warrants lacking meaningful limits were unconstitutional general warrants, suppressed the resulting child-pornography evidence, and reversed Wheeler’s convictions that rested on that evidence.


Wheeler v. State, 135 A.3d 282 (Del. 2016)