When a search warrant is issued for a second time for a defendant's cell phone, what is the difference between the first and second searches?

It makes no difference that the People eventually learned on April 20, 2017, that defendant had disclosed the phone's passcode to a third party. This fact was not known to the investigators when the first search warrant was sought, and it is not clear when defendant gave out the passcode. Because there was no evidence indicating that cell phone 2 was capable of being remotely wiped prior to the first search, it was not unreasonable for the officers to believe the contents of cell phone 2 remained in the same condition as they did when the phone was first seized. Moreover, although the investigators knew about the passcode disclosure prior to the second search, any purported error was harmless beyond a reasonable doubt because no evidence from the second search was admitted at trial. (Chapman v. California (1967) 386 U.S. 18, 24.)

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