United States v. Stevenson, No. 12-3960 (8th Cir. 2013)Annotate this Case
Defendant conditionally pleaded guilty to two counts of possessing child pornography and subsequently appealed the district court's rulings. The court concluded that defendant's Fourth Amendment rights were not violated where a reporting requirement, standing alone, did not transform an Internet service provider, such as AOL, into a government agent whenever it chooses to scan files sent on its network for child pornography; defendant did not demonstrate a contested issue of fact that warranted a hearing; and the district court did not abuse its discretion in granting the motion to quash the subpoena duces tecum that he served on AOL where the subpoena requests were not sufficiently specific.