In United States v. Westfall, --- F.4th ---, No. 24-4515 (9th Cir. 2025), the Court affirmed the district court’s denial of Shayden Bradley Westfall’s motion to suppress evidence seized from searches of his hotel room, vehicles, and phones.
The Missoula Police Department received information from a reliable source that Defendant-Appellant Shayden Bradley Westfall had recently received a distributable quantity of drugs at a Missoula hotel room. After independently corroborating the source’s information, officers obtained a search warrant for the room, where they found methamphetamine, fentanyl, and a firearm. Based on the seizure and Westfall’s incriminating statements following the search, officers obtained another warrant for Westfall’s Facebook records, which were stored at the company’s headquarters in California.Westfall again argues that the evidence from the hotel room and Facebook should be suppressed because the search warrant for the hotel room lacked probable cause, and the Montana state district court lacked jurisdiction to issue a warrant for out-of-state electronic records. Both of Westfall’s arguments fall short. First, law enforcement’s independent corroboration of information obtained from a reliable source gave the issuing judge a substantial basis to conclude that there was sufficient probable cause to issue the search warrant for the hotel room. Second, a Montana district court judge has jurisdiction under the federal Stored Communications Act (“SCA”) and Montana law to issue a search warrant executable for retrieving electronic records stored out-of-state. Accordingly, we affirm the federal district court’s denial of Westfall’s motion to suppress.
