United States v. Goodale, No. 12-3972 (8th Cir. 2013)
Annotate this CaseDefendant appealed his sentence and conviction of five counts including aggravated sexual abuse, interstate transportation of a minor with intent to engage in criminal sexual activity, and accessing child pornography. The court affirmed the district court's denial of defendant's motion to suppress his laptop because the private search exception applied to a search or seizure, even an unreasonable one, effected by a private individual - in this case, the victim - not acting as an agent of the Government or with the participation or knowledge of any governmental official; officers had probable cause to believe the laptop contained contraband based on the victim's and his mother's statements about its internet history, as well as allegations of sexual abuse; the exigencies of the circumstances also demanded seizure; and defendant's statements were not fruit of the poisonous tree. The court also concluded that the evidence was sufficient to support the jury's verdicts on Counts 1, 3, and 4, and the district court properly denied the motion for judgment of acquittal and the motion for a new trial. Finally, the district court did not err, much less plainly err, in applying the U.S.S.G. 4B1.5(b) enhancement and defendant's sentence was substantively reasonable.
Court Description: Criminal case - Criminal law and sentencing. Search fell within the "private search" exception to the Fourth Amendment; officers had probable cause to believe defendant's laptop contained evidence of child pornography offenses and could retain the laptop while awaiting issuance of a warrant; since the search of his laptop did not violate defendant's constitutional rights, his argument that his subsequent statements were fruit of the poisonous tree must be rejected; evidence was sufficient to prove defendant transported a minor over state lines to engage in sexual activity; district court did not err in imposing a five-level enhancement under Guidelines Sec. 4B1.5(b); sentence was substantively reasonable.
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