United States v. Trowbridge

FBI agents went to Jason Trowbridge’s (defendant) home to investigate his involvement in a conspiracy that unlawfully accessed a commercial telephone database to make threatening phone calls, disrupt phone service, and make false 911 calls. When the agents arrived, Trowbridge’s girlfriend told them he was not home. However, the agents could smell marijuana, and they saw two individuals flee by hopping the back fence. Several computers were in the home, along with a wireless router that allowed remote access. The agents called Trowbridge’s cellphone and heard a phone ringing upstairs. While in the house, the agents developed probable cause to search the computers, but they did not have a warrant. Trowbridge had told others that he could take care of investigating police and had also told people to destroy evidence for him in the past. Because of traffic, the agents believed it would be difficult to get a search warrant in time. Ultimately, because they believed Trowbridge could easily destroy the evidence on the computers, they seized the computers without a warrant and checked them into an evidence-control room. Some time later, the agents got a search warrant and discovered incriminating evidence on the computers. At his trial for computer crimes, Trowbridge argued that the warrantless seizure of his computers was unlawful.