The trial court should have granted a motion to traverse a warrant to search defendant’s bank accounts, which were only identified after an improper probation search which terms excluded searches of “financial accounts.” The request should have been brought as a motion to traverse rather than a motion to quash because it challenged the warrant on the basis of material omissions in the affidavit. It was reckless, at best, for the affiant officer to omit the evidence that the Apple Pay account might not be subject to a probation search, as a reasonable person would understand an Apple Pay account to be a financial account.

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/G065769.PDF