New Hampshire v. Letoile
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In 2010, defendant’s ex-wife complained to the Hampstead Police Department that, while using defendant’s computer, she clicked on the browsing history and found disturbing links to websites that potentially contained child pornography. In a follow-up meeting with the police, defendant’s ex-wife explained that she had started checking the defendant’s browsing history six months earlier, and it was at that time that she first noticed child pornography on defendant’s computer. According to the police affidavit for the search warrant, she described the images as depicting “nude young undeveloped girls (well under 18 years of age).” Based upon this information, the police secured a search warrant and seized defendant’s computer. Defendant moved to suppress all evidence and statements obtained as a result of the search warrant, arguing, in part, that the affidavit failed to establish probable cause because it did not provide a sufficient description of the alleged child pornography. After hearing, the superior court granted the motion, ruling that the search warrant did not describe the images with sufficient particularity. Finding no reversible error in the superior court's decision, the Supreme Court affirmed.
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