Dhyne v. People.

2024 CO 45. No. 22SC869. Fourth Amendment—Search Warrants—IP Addresses.

June 17, 2024

This case concerns whether a search for internet-related evidence that extended to a previously unknown basement apartment was reasonable even though the apartment was not specified in the warrant. The Supreme Court held that (1) the warrant’s reference to the property’s “[h]ouse, garage, and any outbuildings” was sufficiently specific because there were no outward indicators that the basement apartment existed, and (2) execution of the warrant was reasonable in this scenario, where the warrant was for all buildings on the property and Dhyne told the police that he lived in the basement and used the IP address that provided grounds for the search.