United States v. Christopher Lee Adjani Jana Reinhold

While executing a search warrant at the home of defendant Christopher Adjani to obtain evidence of his alleged extortion, agents from the Federal Bureau of Investigation seized Adjani’s computer and external storage devices, which were later searched at an FBI computer lab. They also seized and subsequently searched a computer belonging to defendant Jana Reinhold, who lived with Adjani, even though she had not at that point been identified as a suspect and was not named as a target in the warrant. Some of the emails found on Reinhold’s computer chronicled conversations between her and Adjani that implicated her in the extortion plot. Relying in part on the incriminating emails, the government charged both Ad-jani and Reinhold with conspiring to commit extortion in violation of 18 U.S.C. § 371 and transmitting a threatening communication with intent to extort in violation of 18 U.S.C. § 875 (d).

The defendants brought motions to suppress the emails, arguing that the warrant did not authorize the seizure and search of Reinhold’s computer and its contents; but if it did, the warrant was unconstitutionally overbroad or, alternatively, the emails fell outside the scope of the warrant.…