State v. Sawyer
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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress photographs and videos of suspected child pornography that the police recovered from computer equipment and other media storage seized from Defendant's residence pursuant to a search warrant, holding that the search warrant affidavit supported a finding of probable cause.
On appeal, Defendant argued that the search warrant was not supported by probable cause because the issuing judge could not reasonably have inferred from descriptions in the affidavit of two photographs of nude children that the photographs were lascivious. The Supreme Court affirmed, holding that the totality of the circumstances described in the affidavit and the reasonable inferences drawn therefore supported a finding of probable cause to believe that a there was a substantial chance that a search of Defendant's residence would uncover evidence of possession of child pornography. The Court further declined Defendant's invitation to adopt a more demanding standard for assessing whether there is probable cause to issue a search warrant.
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