Whether an officer's uncorroborated belief that co-conspirators who planned a crime over multiple days used their cell phones to do so is a 'bare conclusion' or a 'common-sense judgment

QUESTIONS PRESENTED In Illinois v. Gates, this Court held that a warrant’s issuance “cannot be a mere ratification of the bare conclusions of others,” but also that “warrants are—quite properly—issued on the basis of nontechnical, common-sense judgments of laymen.” 1. Whether an officer’s uncorroborated belief that co-conspirators who planned a crime over multiple days used their cell phones to do so is a “bare conclusion” or a “common-sense judgment” given this Court’s acknowledgment in Riley v. California that cell phones are “a pervasive and insistent part of daily life.” 2. Does the Constitution require a distinct nexus between a cell phone and an offense in order to obtain a search warrant for the device in the context of an organized criminal offense, or is it sufficient that there are nexuses between the device and the offender as well as between the offender and the offense? ii LIST OF PROCEEDINGS Texas Court of Criminal Appeals No. PD-0027-21 The State of Texas v. John Wesley Baldwin Date of Final Opinion: May 11, 2022 Date of Rehearing Denial: July 27, 2022 Court of Appeals of Texas, Fourteenth District No. 14—19-00154-CR The State of Texas v. John Wesley Baldwin Date of Final Opinion: December 10, 2020 208th District Court of Harris County, Texas No. 1527611 The State of Texas v. John Wesley Baldwin Date of Order on Pre-trial Motion to Suppress: January 11, 2019, amended February 11, 2020