Ulbricht was found via the server - all evidence that came as a result of that (including the laptop) would have been dismissed if a 4th amendment appeal was successful.

The only evidence found outside of the server chain was the posts to the Shroomery and Bitcointalk - and as the link in grandparent comment points out, this is not sufficient probable cause for a search warrant (and a search warrant on the Gmail in any case would still not have linked Ulbricht to DPR sufficiently)

[1] right in the second paragraph of article linked in grandparent comment:

> The arrest of Ross Ulbricht got its start when the FBI somehow discovered the real location of the Silk Road server in Iceland.

and

> Every shred of evidence except for two “hey, I found this site” posts derives solely from the server seizure.