In Commonwealth v. Doleras, the Supreme Judicial Court of Massachusetts upheld a warranted search of a defendant’s iPhone photo library and found that the warrant affidavit showed probable cause to justify searching the entire phone. The court, in validating the search warrant, set a narrow scope for Massachusetts’ Fourth Amendment protections against unreasonable searches of smartphones. The court’s decision also highlights the challenge U.S. courts face in defining the bounds of the Fourth Amendment right against unreasonable search and seizure as applied to increasingly sophisticated technology.

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