United States v. Needham, No. 12-50097 (9th Cir. 2013)
Annotate this CaseDefendant pled guilty to possession of child pornography. On appeal, defendant challenged the district court's denial of his motion to suppress. The court concluded, under the good faith exception to the exclusionary rule, that the search in this case was executed in objectively reasonable reliance on the search warrant. Because the court found sufficient ambiguity in the court's precedent, despite United States v. Weber, to confer a grant of qualified immunity in Dougherty v. City of Corvina in 2011, the court was foreclosed from holding that Weber rendered good faith reliance on the warrant in this case impossible in 2010; and defendant's remaining arguments were unavailing. Accordingly, the court affirmed the judgment.
Court Description: Criminal Law. The panel affirmed the district court’s denial of a motion to suppress evidence of child pornography found on the defendant’s iPod during a search of his residence. The panel held that the “good faith” exception to the exclusionary rule announced in United States v. Leon, 468 U.S. 897 (1984), applies where the search was executed in objectively reasonable reliance on a search warrant predicated on the bare inference that those who molest children are likely to possess child pornography. The panel explained that this outcome is controlled by this court’s grant of qualified immunity in an appeal arising from a civil suit in Dougherty v. City of Covina, 654 F.3d 892 (9th Cir. 2011). Judge Berzon concurred only because the outcome is dictated by Dougherty. She would hold that the evidence must be suppressed because the warrant was so lacking in probable cause as to render the officers’ reliance upon it objectively unreasonable. Judge Tallman concurred because the panel’s decision is compelled by existing precedent. If the slate were clean, he would also agree with the issuing magistrate that under the totality of the circumstances, probable cause existed to search the defendant’s home for child pornography.
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