In United States v. Laist, the Eleventh Circuit held that a government delay of 25 days from the defendant's revocation of consent to search a computer until a search warrant application was submitted did not violate the Fourth Amendment.
The distribution of child pornography was tracked to the defendant's home, and law enforcement went to search. Upon arrival, the defendant admitted to possession of child pornography and signed a consent form allowing the search and seizure of his computer. A week later, the defendant withdrew his consent by letter. The search warrant application was submitted 25 days later, and the application was approved six days after submission. The defendant was ultimately convicted of multiple child pornography related crimes.
The government's efforts here were sufficiently diligent to pass muster under the Fourth Amendment. While a 25-day seizure based solely on probable cause is far from ideal, and we have found shorter delays unreasonable under different circumstances, see Mitchell, 565 F.3d at 1352 (21-day delay), the totality of the circumstances in this case demonstrate the reasonableness of the government's actions.