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Commonwealth v. Solis; Commonwealth v. Diaz

2026-08-12

Authorities cited

Opinion

majority opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557-1030; [email protected]

SJC-13823

SJC-13835

COMMONWEALTH vs. JOSE SOLIS.

COMMONWEALTH vs. MICHAEL DIAZ.

Suffolk. January 5, 2026. – August 12, 2026.

Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges,

Dewar, & Wolohojian, JJ.

Cellular Telephone. Constitutional Law, Search and seizure.

Search and Seizure, Warrant. Practice, Criminal, Warrant,

Motion to suppress. Time.

Indictments found and returned in the Superior Court Department on June 26, 2023.

A pretrial motion to suppress evidence was heard by Michael J. Pineault, J.

An application for leave to prosecute an interlocutory appeal was allowed by Gaziano, J., in the Supreme Judicial Court for the county of Suffolk, and the appeal was reported by him to the Appeals Court. The Supreme Judicial Court on its own initiative transferred the case from the Appeals Court.

Indictments found and returned in the Superior Court Department on December 19, 2019.

A pretrial motion to suppress evidence was heard by Sarah Weyland Ellis, J.

2

An application for leave to prosecute an interlocutory appeal was allowed by Lowy, J., in the Supreme Judicial Court for the county of Suffolk, and the appeal was reported by him to the Appeals Court. After review by the Appeals Court, 105 Mass. App. Ct. 809 (2025), the Supreme Judicial Court granted leave to obtain further appellate review.

Brooke Hartley & Cailin M. Campbell, Assistant District Attorneys, for the Commonwealth.

Matthew Spurlock, Committee for Public Counsel Servies, for Jose Solis.

George F. Ohlson, Jr., for Michael Diaz.

The following submitted briefs for amici curiae:

David E. Sullivan, District Attorney, & Nicholas Atallah, Assistant District Attorney, for district attorney for the northwestern district.

Christine A. Monta & Andrew Eslich, of the District of Columbia, Jessie J. Rossman, Jennifer M. Herrmann, & Nathan Freed Wessler for American Civil Liberties Union of

Massachusetts, Inc., & others.

Eric R. Atstupenas for Massachusetts Chiefs of Police Association, Inc.

Michelle Menken & Hannah Taylor for Victor Arrington.

GEORGES, J. These appeals1 require us to decide whether

delays of approximately four months between the lawful seizures

of cell phones incident to arrest and subsequent applications

for warrants to search their contents rendered the continued

seizures of those devices unreasonable under art. 14 of the

Massachusetts Declaration of Rights.

1 Although the two appeals are not consolidated and were argued separately at oral argument, they are addressed in a single opinion because they raise essentially identical questions of law.

3

The defendants, Jose Solis and Michael Diaz, both filed

motions to suppress the evidence obtained from their cell

phones, arguing that the police unreasonably delayed seeking

search warrants. Superior Court judges allowed the motions,

relying on Commonwealth v. White, 475 Mass. 583, 595 (2016),

where we concluded that a sixty-eight day delay in obtaining a

warrant to search a cell phone was unreasonable under the

circumstances presented there.

The delays here, 109 days in Solis's case2 and 123 days in

Diaz's case, exceeded the delay in White. But White rejected

any bright-line temporal rule. White, 475 Mass. at 593.

Instead, it requires courts to balance the defendant's

possessory interest in the seized device against the

Commonwealth's justification for its continued retention under

the totality of the circumstances. Id. at 593-594.

Applying the totality of the circumstances analysis set out

in White, we conclude that the delays in these cases did not

render the continued seizures of the cell phones unreasonable.

See White, 475 Mass. at 593-594, citing United States v. Place,

462 U.S. 696, 703 (1983). See also Commonwealth v. Cruzado, 480

2 Although the motion judge and the parties calculate the delay as 110 days by counting the date of the seizure itself, the relevant inquiry concerns the days following the seizure. See White, 475 Mass. at 585-586. The one-day discrepancy does not affect our conclusion.

4

Mass. 275, 283-284 (2018) (applying standard from White to cell

phone seized under exigent circumstances). The orders allowing

the motions to suppress are reversed.3

Background. We summarize the facts as found by the motion

judges, supplemented by undisputed record evidence consistent

with those findings. See Commonwealth v. Robinson, 497 Mass.

156, 157 (2026).

1. Solis. a. Facts. On March 24, 2023, Chelsea police

responded to a 911 call made by Charlie,4 a thirteen year old who

reported that he had been sexually assaulted by a clerk at a

convenience store in Chelsea. After officers arrived outside

the store, Charlie identified Solis as the clerk who had

assaulted him.

Charlie told responding officers that Solis had forced him

to engage in sexual acts on at least three occasions while at

the store, including once in the store's basement. Charlie

further reported that during one of these incidents, Solis

3 We acknowledge the amicus briefs submitted in support of the defendants by the American Civil Liberties Union of Massachusetts, Inc., the Roderick & Solange MacArthur Justice Center, and the American Civil Liberties Union, Inc.; and Victor Arrington. We also acknowledge the amicus briefs submitted in support of the Commonwealth by the district attorney for the northwestern district. We further acknowledge the amicus brief submitted in support of the Commonwealth in its appeal from the allowance of Diaz's motion to suppress by the Massachusetts Chiefs of Police Association, Inc.

4 A pseudonym.

5

pulled out a cell phone, pointed it at Charlie's exposed

genitals, and appeared to take a photograph. Charlie also

stated that Solis had threatened him with a firearm during one

of the earlier sexual assaults. After obtaining permission to

search the store, officers observed a futon and "bluish blanket"

in the basement, consistent with Charlie's description of where

he was assaulted.

Later that same day, Solis was placed under arrest for,

among other offenses, posing or exhibiting a child in a state of

nudity. See G. L. c. 272, § 29A (a). Immediately prior to his

arrest, Solis handed the police his cell phone (a blue Nokia

"smart" cell phone in a black case) upon their request.

Sergeant Detective Anthony D'Alba of the Chelsea police

department, the supervising detective on call, had recommended

that the police seize Solis's cell phone because it was

"evidence that . . . would be shown to the reported victim" for

identification at trial, and because the cell phone might

contain digital evidence.

Approximately three weeks after the seizure of Solis's cell

phone, Charlie reported during a forensic interview5 that Solis

had used a gray or black Samsung cell phone to photograph his

5 A forensic interview is, as explained by D'Alba, a type of interview that is designed to be "nonsuggestive and nontraumatic for the child."

6

exposed genitals. Around that time, D'Alba began preparing a

warrant application to search the cell phone for evidence of

ownership and the alleged picture.

In the intervening time between Solis's arrest and D'Alba's

submission of the warrant application, D'Alba testified in two

evidentiary hearings, assisted in preparing four or five

Superior Court trials and two District Court matters,

participated in offsite trainings for a total of eight days, and

was unable to work for approximately eight or nine days due to a

serious respiratory infection.

On July 11, 2023, 109 days after the seizure of the cell

phone, D'Alba applied for a warrant to search its contents and

submitted an eighteen-page affidavit in support. The warrant

issued that same day. A subsequent search uncovered a

photograph consistent with Charlie's description.

b. Procedural history. On March 27, 2023, a criminal

complaint issued in the Chelsea Division of the District Court

Department (Chelsea District Court), charging Solis with two

counts of indecent assault and battery on a child under the age

of fourteen, G. L. c. 265, § 13B, and one count of assault by

means of a dangerous weapon, G. L. c. 265, § 15B (b). Two days

later, an additional criminal complaint issued charging Solis

with one count of aggravated assault and battery on a child

under the age of fourteen, G. L. c. 265, § 13B 1/2.

7

On June 26, 2023, a grand jury returned indictments

charging Solis with one count of indecent assault and battery on

a child under the age of fourteen, G. L. c. 265, § 13B; one

count of posing or exhibiting a child in a state of nudity,

G. L. c. 272, § 29A (a); one count of open and gross lewdness

and lascivious behavior, G. L. c. 272, § 16; and one count of

rape of a child between the ages of twelve and sixteen,

aggravated by a more than ten-year age difference, G. L. c. 265,

§ 23A (b).6

In February 2024, Solis moved to suppress evidence obtained

from his cell phone. Following an evidentiary hearing, a

Superior Court judge (Solis's motion judge) allowed the motion,

concluding that the 109-day delay rendered the seizure

unreasonable pursuant to White. The Commonwealth sought and

obtained interlocutory review pursuant to Mass. R. Crim.

P. 15 (a) (2), as amended, 476 Mass. 1501 (2017). The appeal

was entered in the Appeals Court and later transferred to this

court on our own motion.

2. Diaz. a. Facts. From the summer of 2018 to March

2019, Diaz served as the foster parent of two minor children,

6 The Commonwealth subsequently nol prossed the District Court charges.

8

twelve year old Amanda7 and eleven year old Betty,8 who resided

with him in his home during that period.

In June 2019, Amanda disclosed to her biological mother

that Diaz had sexually abused her and that she had observed

similar abuse of Betty. Law enforcement thereafter conducted

forensic interviews of both children, which were attended by

D'Alba of the Chelsea police department.

During her forensic interview on July 16, 2019, Amanda

reported that Diaz sexually assaulted her daily while she lived

in his home. She further reported that the abuse continued

after she was removed from the home. Diaz would communicate

with Amanda via cell phone, coordinating meetings with her

before school, during which time he would rape her. Amanda

informed the interviewer that Diaz had photographed her with his

cell phone, but she could not recall whether she was dressed or

undressed at the time.

Two days later, Betty participated in a separate forensic

interview. Betty likewise reported that Diaz sexually abused

her during the same general time frame. Betty further reported

that Diaz had used his cell phone to show her an image of him

7 A pseudonym.

8 A pseudonym.

9

and his wife engaging in oral sex. Betty confirmed that she had

seen Diaz sexually abuse Amanda.

Based on these interviews, on July 18, 2019, D'Alba applied

for and obtained an arrest warrant from the Chelsea District

Court charging Diaz with several offenses, including

dissemination of matter harmful to a minor, in violation of

G. L. c. 272, § 28. Later that day, officers contacted Diaz on

his cell phone and arranged to meet him at a public location,

where they arrested him pursuant to the warrant. At the time of

his arrest, the defendant possessed a cell phone -- an iPhone 6S

in a distinctive black and copper case with a plastic disk

affixed to the back bearing a United States Army emblem.

Officers seized the device incident to the arrest as it was

believed to be "the device that was used to display the harmful

matter to [Betty]" and because it "contain[ed] evidence that may

be related to [Diaz's] offenses."

About two weeks after Diaz's arrest, in August 2019, D'Alba

learned that Diaz's wife may have also sexually assaulted Betty.

Betty then participated in a second forensic interview, during

which she described an incident in which Diaz used his cell

phone's flashlight while photographing her with her shirt

lifted.

Before applying for a warrant to search Diaz's cell phone,

D'Alba prioritized other responsibilities, managing

10

approximately eighty open sexual assault and child abuse

investigations, while placing the search warrant application on

the "back burner." Once he turned his attention to the

application, however, D'Alba devoted four or five eight-hour

shifts to writing the twenty-seven page affidavit in support of

the search warrant application. In preparing the search warrant

affidavit, D'Alba relied on not only the victims' forensic

interviews, but also the August 2018 and February 2019

investigations by the Department of Children and Families (DCF)

into allegations that Diaz had inappropriately touched Amanda.

On November 18, 2019, 123 days after the seizure of the

cell phone, D'Alba applied for and obtained a search warrant

authorizing the search of Diaz's cell phone. Executing the

search warrant, police recovered a photograph of the defendant

and his wife engaged in oral sex, photographs of Amanda in a

partial state of undress, a photograph of an "unidentified child

with a penis penetrating the child's mouth," and two photographs

of Betty naked.

b. Procedural history. In July 2019, a criminal complaint

issued from the Chelsea District Court, charging Diaz with,

among other things, one count of dissemination of matter harmful

to a minor, G. L. c. 272, § 28.

On December 19, 2019, a grand jury returned thirteen

indictments against Diaz charging him with four counts of rape

11

of a child between the ages of twelve and sixteen, aggravated by

a more than ten-year age difference, G. L. c. 265, § 23A (b);

six counts of indecent assault and battery on a child under the

age of fourteen, G. L. c. 265, § 13B; one count of distribution

of material depicting a child engaged in a sexual act, G. L.

c. 272, § 29B (b); one count of posing or exhibiting a child in

a state of nudity, G. L. c. 272, § 29A (a); and one count of

possession of child pornography, G. L. c. 272, § 29C.9

In October 2022, Diaz moved to suppress evidence obtained

from his cell phone. Following an evidentiary hearing, a

Superior Court judge (Diaz's motion judge) allowed the motion,

concluding that D'Alba's 123-day delay in seeking a search

warrant rendered the cell phone's continued seizure unreasonable

pursuant to White. The Commonwealth obtained leave to pursue an

interlocutory appeal pursuant to Mass. R. Crim. P. 15 (a) (2),

and the case was entered in the Appeals Court.

In a divided decision, the Appeals Court affirmed. See

Commonwealth v. Diaz, 105 Mass. App. Ct. 809, 822 (2025). We

granted the Commonwealth's application for further appellate

review.

9 After the warrant to search Diaz's cell phone had been executed, the District Court charges against Diaz were dismissed by request of the Commonwealth.

12

Discussion. In reviewing a ruling on a motion to suppress,

we accept the motion judge's subsidiary findings of fact absent

clear error and defer to the judge's credibility determinations.

Commonwealth v. Sliech-Brodeur, 457 Mass. 300, 306 (2010). Our

review of the ultimate findings and conclusions of law is

conducted independently. Commonwealth v. Jones-Pannell, 472

Mass. 429, 431 (2015).

Neither defendant disputes that the police lawfully seized

his cell phone incident to arrest. The contested question is

whether the delay in seeking a search warrant rendered the

initially lawful seizure unreasonable. The Commonwealth

contends that the motion judges misread White and that the

police were not required to "diligently obtain" a warrant when

the device itself was evidence of the crime.

1. Balancing test. Article 14 guarantees that "[e]very

subject has a right to be secure from all unreasonable searches,

and seizures, of his person, his houses, his papers, and all his

possessions." A seizure that is "reasonable at its inception

. . . may become unreasonable as a result of its duration"

(citation omitted). White, 475 Mass. at 593.

To assess whether a delay in seeking a warrant to search a

cell phone has crossed that line, we balance "the nature and

quality of the intrusion on the individual's [possessory]

interests against the importance of the governmental interests

13

alleged to justify the intrusion." White, 475 Mass. at 593-594,

quoting Place, 462 U.S. at 703. The inquiry turns on the

totality of the circumstances. See United States v. Laist, 702

F.3d 608, 613 (11th Cir. 2012).

In White, 475 Mass. at 593-595, we applied this balancing

framework to a sixty-eight day delay between the seizure of a

cell phone and the application for a warrant to search it.

Because the motion judges relied on White in allowing the

defendants' motions, we briefly describe the facts underlying

that decision before turning to the materially different records

before us.

In White, the police were investigating an armed robbery

and shooting. Id. at 584. Three days after the incident, one

of the defendant's high school administrators confiscated his

cell phone under school policy. Id. at 585-586. Later that

same day, the police took the cell phone from the school. Id.

at 586. Although the police suspected that the defendant was

involved in the robbery and had used the cell phone to

coordinate with his suspected coventurers, they did not apply

for a search warrant until sixty-eight days after they seized

the device. Id. at 584, 590.

The reasonableness analysis in White rested on several

related factors. Although the police lacked probable cause to

seize the cell phone, we assumed probable cause for purposes of

14

evaluating the delay. See id. at 584-585 ("We conclude that

. . . the seizure here was not supported by probable cause. We

separately conclude also that, in these circumstances, the

Commonwealth has not, in any event, met its burden of

demonstrating" that delay in seeking search warrant was

reasonable [emphasis added]). The police also failed to treat

the warrant application as a priority. See id. at 594.

Additionally, the Commonwealth offered no warrant-specific

justification for the sixty-eight day delay regarding either the

complexity of the investigation or the demands of the

application. See id. at 594-595. Taken together, those

circumstances left the Commonwealth with a minimal interest in

retaining the device, one that could not justify the substantial

delay, which "affects [not] only the person's possessory

interest[], but also the ability of the judiciary promptly [to]

evaluat[e] and correct[] improper seizures" (quotations and

citation omitted). Id. at 595.

The fact that the delays here exceed the sixty-eight day

delay in White does not determine the outcome. See White, 475

Mass. at 593 ("no bright line past which a delay becomes

unreasonable" [citation omitted]). See also Laist, 702 F.3d at

614 (cautioning that, given fact-intensive nature of inquiry, it

is "unwise to establish a duration beyond which a seizure is

definitively unreasonable or . . . even presumptively

15

unreasonable"). These cases differ from White in material

respects. Unlike in White, supra at 592, the police here had

probable cause to seize the devices, and the devices had

evidentiary significance apart from the data they might contain.

See Cruzado, 480 Mass. at 284 (distinguishing White based on

existence of probable cause to seize). See also Commonwealth v.

Arthur, 94 Mass. App. Ct. 161, 165-166 (2018) (distinguishing

White based on, among other things, independent evidentiary

value of seized devices). The question remains whether, under

the totality of the circumstances, each defendant's possessory

interest outweighs the Commonwealth's justification for

continuing to retain his cell phone.

With White properly framed, we turn to the three

considerations that guide the balancing inquiry here: the

defendants' possessory interest in the seized cell phones, the

extent of the governmental intrusion on that interest, and the

strength of the Commonwealth's justification for continuing to

retain the devices.

a. Possessory interest. When examining a defendant's

interest in a cell phone that has been subject to a delayed

search, we specifically consider his or her possessory interest.

See Cruzado, 480 Mass. at 284 ("Judged against the defendant's

minimal possessory interest, the governmental interests

16

justified a ten-day delay" [emphasis added]).10 Cell phones,

like computers, may implicate a substantial possessory interest.

See Laist, 702 F.3d at 614 (persons may have powerful possessory

interest in computers). See also Commonwealth v. Phifer, 463

Mass. 790, 797 (2012) ("today's cellular telephones are

essentially computers"). They often store a wide range of

personal information, including communications, financial data,

location data, and photographs. See Riley v. California, 573

U.S. 373, 396 (2014) ("Historic location information is a

standard feature on many smart phones" and can "reveal where a

person has been"); United States v. Mitchell, 565 F.3d 1347,

1351 (11th Cir. 2009). There is a significant likelihood that

10This approach is consistent with the analysis applied under the Fourth Amendment to the United States Constitution by multiple United States Circuit Courts of Appeals. See, e.g., United States v. Mays, 993 F.3d 607, 617 (8th Cir. 2021) ("On the private-interests side, relevant considerations include the significance of the interference with the person's possessory interest . . ."); United States v. Smith, 967 F.3d 198, 206 n.1 (2d Cir. 2020) (acknowledging that other United States Circuit Courts of Appeals use "similar relevant factors" to also "balance the individual's possessory interest against the government's continuing interest in retaining the property for investigation or prosecution"); United States v. Pratt, 915 F.3d 266, 271 (4th Cir. 2019) ("To determine if an extended seizure violates the Fourth Amendment, we balance the government's interest in the seizure against the individual's possessory interest in the object seized"); United States v. Burgard, 675 F.3d 1029, 1033 (7th Cir.), cert. denied, 568 U.S. 852 (2012) ("On the individual person's side of this balance, the critical question relates to any possessory interest in the seized object, not to privacy or liberty interests").

17

"much of the data on the device that has been seized will be

deeply personal and have nothing to do with the investigation of

criminal activity." United States v. Smith, 967 F.3d 198, 207

(2d Cir. 2020). As a result, a person's possessory interest in

certain personal electronic devices, like the "smart" cell

phones (smartphones) here,11 is different in kind from the

possessory interests one may have in other personal belongings.

See id. at 208 ("vital" consideration to assessing importance of

seized property of defendant that personal electronic devices

"implicate[] different privacy and possessory concerns" from

other personal property). See also Riley, supra at 393

(argument that search of data on cell phone is materially

indistinguishable from search of physical items is "like saying

a ride on horseback is materially indistinguishable from a

flight to the moon. Both are ways of getting from point A to

point B, but little else justifies lumping them together").

While a person's possessory interest in a smartphone

generally may be substantial, in determining the reasonableness

of a delay, we must examine the circumstances of each case. See

Smith, 967 F.3d at 208 ("Notwithstanding the distinctive

11A smartphone can make telephone calls, send text

messages, operate as both a camera and video recorder, operate various applications, and connect to the Internet. Commonwealth v. Dorelas, 473 Mass. 496, 497 n.1 (2016).

18

qualities of [defendant's] tablet as a personal electronic

device," facts demonstrated diminished importance of seized

tablet to defendant, weighing in government's favor). The

record may show that the possessory interest is reduced.

Relevant circumstances may include whether the defendant

requested the cell phone's return; whether the record shows a

defendant's concrete need for the device for work, family,

financial, medical, or other daily obligations; the strength of

the defendant's claim of ownership; whether officers permitted

the defendant the opportunity to copy or remove personal content

from the cell phone before the seizure; the defendant's

ownership of another cell phone with equivalent functionality;

and the defendant's admission that the cell phone contains

illicit material. See, e.g., Cruzado, 480 Mass. at 283-284

(strength of claim of ownership); Smith, 967 F.3d at 206, 208

(demonstrated importance of seized device and ownership of

functionally equivalent device); United States v. Sullivan, 797

F.3d 623, 633-634 (9th Cir. 2015), cert. denied, 578 U.S. 1024

(2016) (failure to seek return of seized device); Laist, 702

F.3d at 616 (opportunity to copy contents and admission of

illicit contents).

b. Significance of the intrusion. After assessing a

defendant's possessory interest in a cell phone, we determine

the extent of the governmental intrusion, including the length

19

of delay and whether the defendant consented to the seizure.

See Laist, 702 F.3d at 613-614; United States v. Stabile, 633

F.3d 219, 235 (3d Cir.), cert. denied, 565 U.S. 942 (2011) (no

infringement of possessory interest where defendant consents to

seizure). Although the length of delay carries significant

weight in our analysis, no bright-line rule defines when a delay

becomes unreasonable. See Cruzado, 480 Mass. at 283. Indeed,

courts have upheld delays of several months in some

circumstances, while finding shorter delays unreasonable in

others. Compare, e.g., Arthur, 94 Mass. App. Ct. at 165-166

(eighty-five day delay reasonable), United States v. Burris, 22

F.4th 781, 785 (8th Cir. 2022) (eight months reasonable), United

States v. Wells, 804 F. Supp. 3d 1000, 1009-1010 (D. Neb. 2025)

(six months reasonable), and United States v. Blanchard, 544 F.

Supp. 3d 166, 172 (D. Mass. 2021) (four months reasonable), with

United States v. Pratt, 915 F.3d 266, 273 (4th Cir. 2019)

(thirty-one days unreasonable), and Mitchell, 565 F.3d at 1353

(twenty-one days unreasonable).

c. Government's interest. We next identify the

government's interest that justifies the continued seizure and

weigh it against the intrusion on the defendant's possessory

interest. See White, 475 Mass. at 593-594.

In evaluating the government's interest, we consider

various factors, including the basis for the seizure of the cell

20

phone;12 the device's evidentiary value independent of its

contents; the nature of the offense; the strength of the

government's justification for the delay as demonstrated by the

complexity of the investigation and the effort required to

obtain a warrant; the use of secure storage to prevent remote

destruction of evidence; and whether police acted diligently.

See, e.g., Cruzado, 480 Mass. at 284 (nature of crime); White,

475 Mass. at 594 (diligence in obtaining warrant); United States

v. Sykes, 65 F.4th 867, 879 (6th Cir. 2023), cert. denied, 144

S. Ct. 576 (2024) (secure storage of device); Burris, 22 F.4th

at 785 (independent evidentiary value of device); United States

v. Mays, 993 F.3d 607, 617-618 (8th Cir. 2021) (probable cause

to seize and effort required to obtain warrant); Smith, 967 F.3d

at 210-211 (strength of justification for delay); Laist, 702

F.3d at 617 (investigation's scope and complexity).

One factor -- independent evidentiary value -- has been

treated by some Federal courts as effectively dispositive under

the Fourth Amendment to the United States Constitution. See

Burris, 22 F.4th at 785. See also Smith, 967 F.3d at 209

(acknowledging that if defendant's tablet had independent

12Because "[t]he [S]tate has a stronger interest in

seizures made on the basis of probable cause than in those resting only on reasonable suspicion," greater delays are tolerated after probable-cause seizures. Burgard, 675 F.3d at 1033.

21

evidentiary value, such value "would have justified the police's

retention of the tablet without regard" to search warrant

application). Under that approach, when a lawfully seized cell

phone is evidence of the crime, any delay in obtaining a warrant

to search its contents is considered "immaterial." Burris,

supra. The rationale is straightforward. Because the

government may retain the device itself as evidence for trial,

its continued possession does not depend on what a search of the

device's contents might reveal. A delay in searching the

contents therefore does not postpone the owner's recovery of the

device. By contrast, where a device has no evidentiary

significance apart from its potential digital contents, "the

government would be obligated to return" the device if the

search "reveal[s] no such incriminating evidence." Mitchell,

565 F.3d at 1352.

We decline to adopt this categorical approach under art.

14. See Commonwealth v. Augustine, 467 Mass. 230, 244 (2014),

S.C., 470 Mass. 837 and 472 Mass. 448 (2015) (art. 14 may afford

greater substantive protection than Fourth Amendment). Such a

rule would sweep too broadly, treating the police's burden to

seek a warrant as fully discharged the moment a device qualifies

as evidence. That premise is in tension with the central role

that cell phones play in modern life. See Commonwealth v.

Cronin, 495 Mass. 170, 180 (2025) (cell phones are

22

"ubiquitous"); Commonwealth v. Hobbs, 482 Mass. 538, 546 (2019)

("cell phones have become an indispensable part of daily life"

[quotation and citation omitted]). The longer a device sits in

police custody, the longer its owner is deprived of access to

records, communications, and tools on which daily life

increasingly depends. See United States v. Burgard, 675 F.3d

1029, 1033 (7th Cir.), cert. denied, 568 U.S. 852 (2012). That

deprivation has constitutional weight, even where a judge

ultimately determines that the Commonwealth has a substantial

independent basis for retention, because avoidable delays

disserve the judiciary's role in promptly "evaluat[ing] and

correct[ing] improper seizures" when they do occur (citation

omitted). White, 475 Mass. at 595. Accordingly, a cell phone's

independent evidentiary value may substantially strengthen the

Commonwealth's interest in retaining the device, but it does not

excuse neglect, and it does not permit extended delay in every

case.

2. Application. We now apply that balancing test to each

case before us, starting with Solis's case.

a. Solis. i. Possessory interest. Solis's possessory

interest was substantial at the outset because the seized item

was a smartphone. On this record, however, that interest was

diminished in two respects. First, the record offers no

indication, and Solis does not contend, that he sought the

23

return of his cell phone. See Sullivan, 797 F.3d at 633-634,

quoting United States v. Johns, 469 U.S. 478, 487 (1985) (person

who "never sought return of the property" had not made

sufficient showing that delay was unreasonable). See also Rule

61 of the Rules of the Superior Court (1980) (governing motions

for return of property); United States v. Nkongho, 107 F.4th

373, 384 (4th Cir.), cert. denied, 145 S. Ct. 776 (2024)

(defendant's possessory interest was "no doubt high" where,

among other things, she and her attorney "contacted law

enforcement to request that [her devices] be returned").

Second, the record contains no evidence that the cell phone held

any "particular significance" to Solis. Smith, 967 F.3d at 208

(defendant's testimony about use and significance of device was

"spare in detail"). Contrast United States v. Eisenberg, 707 F.

Supp. 3d 406, 415 (S.D.N.Y. 2023) (defendant showed particular

significance by explaining his "extensive[]" use of devices to

communicate with friends and to store "large amount of personal

and business data" and that devices contained information for

accessing funds). Taken together, these considerations reduce,

but do not eliminate, the weight of Solis's possessory interest.

ii. Extent of intrusion. Although Solis's possessory

interest was diminished, "[p]ossessory interest is only one

factor to be considered in the over-all reasonableness

calculus." White, 475 Mass. at 595. We also consider the

24

extent of the government's intrusion on Solis's interest in the

seized cell phone. The 109-day delay in Solis's case

constitutes a significant intrusion on his possessory interest.

See Laist, 702 F.3d at 616 (twenty-five day delay was "not

insubstantial"). Solis did not consent to the initial seizure,

which otherwise could have minimized or negated any intrusion on

his possessory interest. See Sullivan, 797 F.3d at 634

("minimal" interference with possessory interest where, among

other things, defendant consented to ongoing seizure); Stabile,

633 F.3d at 235 (no infringement of possessory interest where

defendant consented to seizure).13

iii. The government's interest in seizing and retaining

Solis's cell phone. Several factors strongly support the

government's interest. First, the police had probable cause to

seize the cell phone, a "key factor" in the analysis (citation

omitted). Mays, 993 F.3d at 617. At the time of Solis's arrest

and the seizure of his cell phone, the police were aware of

Charlie's report that Solis had used a cell phone to photograph

Charlie's genitals during one of several sexual assaults. They

were also aware that, according to Charlie, one of the incidents

13As neither defendant here consented to the initial seizure, we need not determine the exact impact consent may have on the "nature and quality of the intrusion" (citation omitted). White, 475 Mass. at 593-594.

25

occurred in a room in the store's basement containing a bed with

a "bluish blanket." Charlie's account was corroborated by the

officers' subsequent observation of a futon and "bluish blanket"

in the store's basement. These facts established probable cause

to seize Solis's cell phone.

Based on these same facts, the cell phone also had

meaningful evidentiary value independent of its contents: it

was allegedly used to commit the offense of posing a child in a

state of nudity. See Burris, 22 F.4th at 785 (where cell phone

had independent evidentiary value, eight-month delay was not

unreasonable). That value did not depend on what a later search

of the cell phone might reveal. A conviction under G. L.

c. 272, § 29A (a), does not require proof that the photograph

was successfully created, and the device itself may serve as

corroborating evidence if successfully identified by the victim.

See Commonwealth v. Bresilla, 470 Mass. 422, 430 (2015)

(identification of tangible objects seen during crime by

percipient witness provides "indirect evidence of the

defendant's guilt"); Commonwealth v. Lawrence, 68 Mass. App. Ct.

103, 105 (2007) (violation of G. L. c. 272, § 29A [a], does not

require successful creation of photograph).14

14We do not ignore the discrepancy between the blue Nokia smartphone in a black case seized from Solis and Charlie's later description of a gray or black Samsung cell phone. That discrepancy weakens the cell phone's independent evidentiary

26

The government's interest is further strengthened by the

nature of the offense, which involves the sexual exploitation of

a child, an area in which the Commonwealth's interest is

"particularly strong." Cruzado, 480 Mass. at 284. Cf.

Commonwealth v. Feliz, 486 Mass. 510, 517 (2020) ("Preventing

sexual exploitation and abuse of children constitutes a

government objective of surpassing importance" [quotation and

citation omitted]).

Countervailing considerations diminish the weight of the

government's interest. The case was relatively straightforward,

involving a single victim and a single defendant. More

importantly, the Commonwealth's justification for the delay

reflects a lack of warrant-specific diligence. Some initial

delay could be attributed to the timing of the victim's forensic

interview, but most of the remaining time was attributed to the

value. It does not eliminate that value, however, because Charlie initially reported that Solis used the cell phone during the sexual assault, the seized cell phone matched the general color when covered with its case, and probable cause does not require certainty about identification at trial. Cf. United States v. Smith, 9 F.3d 1007, 1014 (2d Cir. 1993) (minor inconsistencies in informant's description did not undermine probable cause); Ellis v. United States, 264 F.2d 372, 374 (D.C. Cir.), cert. denied, 359 U.S. 998 (1959) (probable cause existed where descriptions shared basic similarities and fairly matched suspect). Moreover, because "tangible objects are typically not unique," Bresilla, 470 Mass. at 430, it is not necessarily fatal to the cell phone's independent evidentiary value that the cell phone was, as Solis's motion judge described it, "nondescript."

27

officer's general workload and the department's staffing

constraints. Generalized workloads do not excuse delay. See

White, 475 Mass. at 594.

The effort required to prepare the warrant application

likewise does not justify the delay. See Mays, 993 F.3d at 618.

Although the affidavit spanned eighteen pages, only a limited

portion contained case-specific facts. Unlike more complex

cases involving multiple agents or extended investigations, the

affidavit here drew on a limited set of sources and did not

require substantial investigative synthesis. Contrast id.

(eighteen-page affidavit supported reasonableness where affiant

compiled specific information about defendant's alleged conduct

from four separate investigative teams); Laist, 702 F.3d at 617

(three pages of information was "very substantial" where affiant

compiled information from "numerous [Federal Bureau of

Investigation] agents" related to year-long investigation).

The police did not act with the diligence that art. 14

demands. Investigative workload alone cannot justify extended

delay; the Commonwealth must identify warrant-specific reasons

for the lapse. See White, 475 Mass. at 594. That said, lack of

diligence does not end the inquiry where other circumstances

provide a continuing, case-specific basis to retain the device.

See Cruzado, 480 Mass. at 283 n.9. Cf. Asinor v. District of

Columbia, 111 F.4th 1249, 1260 (D.C. Cir. 2024) (government "can

28

reasonably retain contraband or evidence in an ongoing criminal

investigation or trial"). The point is not that diligence

becomes optional. It is that the absence of diligence must be

weighed with the remaining facts.

iv. Balancing the interests. On this record, the 109-day

delay did not render the seizure of Solis's cell phone

unreasonable. This conclusion rests on the combined force of

several factors, not on any single factor. The police had

probable cause to believe that the device was an instrumentality

of a serious felony involving child sexual abuse; the cell phone

carried meaningful evidentiary value independent of its

contents, particularly where Charlie could identify it at trial,

subject to the discrepancy in his later description; Solis never

sought the device's return; and Solis offered no evidence that

it held any particular significance to him. Although the

Commonwealth's interest was tempered by the lack of diligence,

it remained substantial. The continued seizure was therefore

reasonable.

b. Diaz. i. Possessory interest. Diaz's possessory

interest was substantial at the outset for the same reason: the

seized item was a smartphone. Like Solis, however, Diaz did not

request the return of his cell phone, which reduces the weight

of his possessory claim, but does not defeat it. See Sullivan,

797 F.3d at 633. Diaz also failed to present any evidence that

29

the cell phone held any particular importance to him. See

Smith, 967 F.3d at 208. Contrast Eisenberg, 707 F. Supp. 3d at

415. As in Solis's case, Diaz's possessory interest, while

real, carries reduced weight in the balance.

ii. Extent of intrusion. The 123-day delay in Diaz's case

constitutes a substantial intrusion on his possessory interest.

See Laist, 702 F.3d at 616. As with Solis, Diaz did not consent

to the seizure of his cell phone. See Sullivan, 797 F.3d at

634; Stabile, 633 F.3d at 235.

iii. The government's interest in seizing and retaining

Diaz's cell phone. Here, the government's interest in Diaz's

cell phone was also substantial, particularly at the time of the

initial seizure. The police had probable cause to seize Diaz's

cell phone incident to his arrest -- again, a "key factor" in

the analysis (citation omitted). Mays, 993 F.3d at 617. See

Cruzado, 480 Mass. at 284. Diaz argues, however, that because

it is "common for an individual to carry two or more [cell]

phones," it was unreasonable to infer that the device seized

incident to his arrest was the same one used in the alleged

offenses, particularly in the absence of any description of the

cell phone from the victims. See United States v. Fletcher, 978

F.3d 1009, 1016-1017 (6th Cir. 2020) ("possessing more than one

cell phone is a practice common in the general public"). As a

30

result, Diaz contends, the seized cell phone cannot have any

evidentiary value independent of its contents. We disagree.

Diaz was arrested for, among other things, dissemination of

matter harmful to a minor, in violation of G. L. c. 272, § 28.

At the time of his arrest, the police were aware from forensic

interviews that Diaz had used his cell phone to display to Betty

a sexually explicit photograph of himself and his wife.

Immediately before the arrest, D'Alba called Diaz on his cell

phone and asked him to come outside; Diaz did so, holding a cell

phone in his hand.

In these circumstances, it was reasonable to infer that the

seized cell phone was the same device used in the crime of

arrest. Although the police lacked a specific description of

the cell phone, they could rely on "normal inferences" regarding

where the at-issue cell phone might have been found (citation

omitted). White, 475 Mass. at 589. Those inferences were

especially strong here because D'Alba called Diaz on his cell

phone immediately before the arrest, Diaz came outside in

response to that call, and Diaz was holding a cell phone when

officers arrested him. See Augustine, 467 Mass. at 246 (cell

phones "physically accompany their users everywhere -- almost

permanent attachments to their bodies"). Cf. Commonwealth v.

James, 424 Mass. 770, 777-778 (1997) (probable cause supported

belief that instrumentalities of crime were located within

31

defendants' homes where items were "durable, of continuing

utility to the defendants, and . . . not inherently

incriminating to possess").

The general possibility that Diaz possessed several cell

phones does not defeat probable cause. Probable cause "deal[s]

with probabilities," not certainties, and does not require proof

"beyond a reasonable doubt" that the seized device was the one

used in the crimes (citation omitted). Commonwealth v. Kaupp,

453 Mass. 102, 110–111 (2009). The facts known to the police at

the time of arrest provided probable cause to believe that the

seized cell phone was an instrumentality of the dissemination

offense for which Diaz was arrested. Consequently, the seized

cell phone also had significant evidentiary value independent of

its contents. See Burris, 22 F.4th at 785. Diaz's purported

use of the cell phone as the instrumentality by which he

disseminated matter harmful to a child carries particular weight

given that a conviction under G. L. c. 272, § 28, does not

require the Commonwealth to produce the offending material

itself. See Ferrari v. Commonwealth, 448 Mass. 163, 169 (2007)

(holding evidence was sufficient to convict under G. L. c. 272,

§ 28, where Commonwealth relied solely on child's testimony as

to entire contents of "porn" videotapes she personally

observed). The government's interest is further strengthened by

32

the nature of the offenses, which involve the sexual

exploitation of children. See Feliz, 486 Mass. at 517.

Additionally, the cell phone acquired further independent

evidentiary value after its seizure.15 In a subsequent forensic

interview, Betty reported that Diaz had used his cell phone to

photograph her while her shirt was lifted. The device itself

thus became evidence of two offenses, dissemination and posing,

further strengthening the governmental interest in retaining it.

See Burris, 22 F.4th at 785. Also, the police reasonably could

infer from the forensic interviews that the victims would be

able to identify the device at trial, thereby corroborating

their allegations and providing circumstantial evidence of

Diaz's guilt. See Bresilla, 470 Mass. at 430.

D'Alba's admission that the warrant application was placed

"on the back burner" directly contravenes the requirement that

warrant applications for digital devices be prioritized, see

White, 475 Mass. at 593, and weighs against the Commonwealth's

interest. The police investigation, however, was more complex

than in Solis's case. It spanned nearly half a year, involved

15We may consider these developments because the police did not obtain this information as a result of the continued seizure of the cell phone. See Commonwealth v. Oliveira, 474 Mass. 10, 16 (2016) (seizure "cannot be justified by information learned from the seizure").

33

multiple victims, and drew on information from several sources,

including prior related DCF investigations and multiple forensic

interviews. That complexity bears on the time reasonably

required to prepare a warrant application. See Laist, 702 F.3d

at 617.

The effort required to prepare the affidavit likewise

supports the Commonwealth's interest. See Mays, 993 F.3d at

617. D'Alba's twenty-seven page affidavit included extensive,

case-specific information drawn from multiple investigations and

agencies. Unlike in Solis's case, the affidavit here reflected

a substantial synthesis of evidence developed over an extended

period. See id.; Laist, 702 F.3d at 617. D'Alba's testimony

that he devoted four or five eight-hours shifts to drafting the

application is consistent with the scope of the investigation

and does not reflect undue delay. See Laist, supra at 614.

iv. Balancing the interests. In Diaz's case, the 123-day

delay did not render the seizure of Diaz's cell phone

unreasonable. The device was not merely a repository of

evidence. It was allegedly used as an instrumentality of

offenses involving the sexual abuse of children, and its

evidentiary significance -- independent of its contents -- was

present at the time of seizure and grew with subsequent

investigative developments. Diaz's possessory interest was also

diminished, both by his failure to seek the return of the device

34

and by the absence of any record evidence that the cell phone

was important to him. These facts do not make the length of the

delay immaterial. They do, however, give the Commonwealth a

continuing case-specific basis to retain the device while the

warrant application was prepared, which, in turn, acts as a

countervailing consideration to the length of the delay.

The delay in seeking the warrant exceeded the delay in

Solis's case, and, by D'Alba's own admission, the warrant

application was not prioritized. The lack of prioritization is

serious and weighs against the reasonableness of the delay.

Still, "we have never said that [diligence] is a dispositive

factor." Cruzado, 480 Mass. at 283 n.9. Here, the delay is

mitigated by the greater complexity of the investigation, the

substantial effort required to prepare the twenty-seven page

affidavit (including the synthesis of information from multiple

forensic interviews and prior investigations), and, importantly,

the device's continuing evidentiary value in relation to the

charged offenses. On balance, the Commonwealth's interest

outweighed the intrusion on Diaz's possessory interest.

Conclusion. The motion judges erred in concluding that the

delays in seeking warrants rendered the seizures unreasonable.

The orders allowing the motions to suppress are reversed, and

the matters are remanded to the Superior Court.

35

Nothing in this opinion should be read to condone delay.

Article 14 requires that applications for warrants to search

digital devices be treated as a priority, not as an

afterthought. Our holding is narrow, and rests on the

combination of probable cause, a continuing evidentiary basis

for retaining the cell phones apart from their contents, serious

offenses involving child sexual exploitation, and diminished

possessory interests.

So ordered.