United States v. Crespo-Rios, No. 09-2252 (1st Cir. 2011)
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The defendant had sexually explicit online conversations with an officer posing as a 12-year old girl. Agents obtained a warrant to search his residence for evidence of violation of 18 U.S.C. 1470 (transfer of obscene material to a minor) and 18 U.S.C. 2422(b) (coercion or enticement of a minor), seized a computer system and cds, and found child pornography. Defendant was charged with transferring obscene material to a minor under age 16 (18 U.S.C. 1470) and possession of child pornography (18 U.S.C. 2252(a)(4)(B)). The district court granted a motion to supress, holding that the agents lacked probable cause to search for child pornography. The First Circuit reversed, based on the inevitable discovery doctrine. The agents had probable cause to search the digital media and, in searching for evidence of interaction with minors, had to thoroughly search the electronic files.
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