Is this strictly true? I feel like the evidence that a photo was present on specific device is different from evidence that a photo was uploaded by a specific account (and a specific ip address probably).
It seems like it would be far easier for the government to justify a search warrant if they have evidence the photo they are looking for was on a specific device. Just having evidence that a specific account uploaded a photo seems like far shakier grounds to search a specific device, after all accounts are often stolen to be used for criminal purposes and ip addresses don't map cleanly to people or devices.