The Louisiana Supreme Court affirmed a lower court's ruling that allowed cell phone evidence to be used in the criminal prosecution of Leonidas Lowry, also known as "Chico," in a per curiam decision issued Oct. 24, 2025.

The court held that the trial court properly denied Lowry's motion to suppress evidence obtained from his cell phone, ruling that law enforcement followed proper procedures under Louisiana Code of Criminal Procedure Article 163. The decision provides important guidance on how digital evidence extraction should be handled in criminal cases.

In *State of Louisiana v. Leonidas Lowry* (La. 2025), the Louisiana Supreme Court applied de novo review to the legal conclusions involved in the motion to suppress, citing *State v. Donald* (La. 2013) as precedent for this standard of review. The court examined whether the seizure and subsequent analysis of Lowry's cell phone complied with state criminal procedure requirements.

The court found that law enforcement acted within legal bounds when they seized Lowry's cell phones pursuant to valid search warrants. Crucially, the phones were "promptly placed in secure evidence lockers within the 10-day window set by La.C.Cr.P. art. 163(C)," the court wrote, demonstrating compliance with the statutory timeline for securing seized electronic devices.

The opinion addressed the timing of digital evidence extraction, a key issue in modern criminal procedure. Under Louisiana Code of Criminal Procedure Article 163(D)(2), which was in effect at the time of the offense and when the search warrant was issued, "any examination or testing of the seized property may be conducted at any time before or during the pendency of any criminal proceeding in which the property may be used as evidence."

The court drew an analogy between digital and physical evidence, explaining that "the extraction of data from an electronic device, such as the defendant's phone, is done to permit examination of its contents, which the law provides may be done at any time before or during the pendency of the criminal proceeding." The justices compared this process to "the seizure of paper documents for later review of their contents by investigators."

This reasoning reflects the court's approach to adapting traditional evidence rules to modern digital contexts. By treating data extraction as analogous to examining physical documents, the court provided a framework for law enforcement agencies handling electronic evidence in criminal investigations.

The case originated in Jefferson Parish and was reviewed by the Fifth Circuit Court of Appeal before reaching the Louisiana Supreme Court on a writ of certiorari. The per curiam nature of the decision indicates that the court viewed the legal principles as well-established, though Chief Justice Weimer issued a partial dissent and partial concurrence with assigned reasons, and Justice Hughes concurred with assigned reasons.

The timing requirements under Louisiana Code of Criminal Procedure Article 163(C) played a central role in the court's analysis. This provision requires law enforcement to secure seized property within 10 days, a deadline that becomes particularly important for electronic devices that may contain vast amounts of digital evidence.

The court's ruling clarifies that compliance with the initial 10-day secure storage requirement does not restrict when the actual examination of digital contents may occur. This interpretation provides law enforcement with flexibility in processing electronic evidence while maintaining procedural safeguards.

The decision has implications for criminal defense attorneys challenging digital evidence in Louisiana courts. The ruling suggests that challenges based on the timing of data extraction alone are unlikely to succeed if the initial seizure was conducted under valid warrants and the devices were properly secured within the statutory timeframe.

For law enforcement agencies, the decision provides clearer guidance on handling electronic evidence. The court's analysis reinforces that following proper warrant procedures and meeting statutory deadlines for evidence storage will generally protect subsequent digital forensics work from suppression motions.

The case reflects broader trends in criminal procedure law as courts nationwide grapple with how traditional Fourth Amendment protections and state criminal procedure rules apply to digital evidence. Louisiana's approach, as articulated in *Lowry*, emphasizes adherence to existing procedural frameworks while recognizing the unique aspects of electronic evidence.

The opinion's comparison between digital and physical evidence examination may influence future cases involving electronic devices. By establishing this analogy, the court provided a conceptual framework that other Louisiana courts can apply when addressing similar digital evidence questions.

While the per curiam decision was brief, its affirmance of the lower court's ruling sends a clear signal about Louisiana's approach to digital evidence in criminal cases. The decision reinforces that proper warrant procedures and compliance with evidence storage requirements will generally support the admissibility of digital evidence obtained from electronic devices.