Commonwealth v. Solis; Commonwealth v. Diaz

Summary

The court held that four-month delays in obtaining warrants to search cell phones lawfully seized incident to arrest did not make the continued seizures unreasonable under art. 14. Applying a totality-of-the-circumstances balancing test, the court weighed the defendants' possessory interests and the duration of the intrusion against probable cause, the phones' independent evidentiary value, the seriousness and complexity of the investigations, and the Commonwealth's justification for the delays. The suppression orders were reversed and the matters were remanded.