People v. Rowland
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Detective Nava obtained a search warrant for Rowland’s residence. Nava had investigated a report from Sergeant Dahl, a member of the Silicon Valley Internet Crimes Against ChildrenTask Force. Dahl was investigating Cybertips from the National Center for Missing and Exploited Children (NCMEC), which had received anonymous Cybertips from a Microsoft Online Operation employee who viewed files of apparent child pornography, which were uploaded from a particular IP address. The Child Victim Identification Program confirmed that the person from Cybertip 1 had been identified and was underage at the time the photograph was taken. Dahl learned the IP address was assigned to AT&T, obtained a search warrant, and learned the subscriber was Rowland. Charged with possessing or controlling matter depicting a person under 18 years of age personally engaging in or simulating sexual conduct, Rowland unsuccessfully moved to quash the search warrant that led to the seizure of his electronic devices, including a thumb drive that contained about 1,000 images and 25 videos of child pornography.
The court of appeal affirmed. Although the search warrant affidavit did not name the employee who submitted the cybertips to NCMEC or the person who forwarded the cybertips from NCMEC to the police, the totality of the circumstances supported a determination that the cybertips came from unbiased citizen informants who could be presumed reliable and thus did not need independent corroboration.
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