United States v. Farlow, No. 11-1975 (1st Cir. 2012)Annotate this Case
After defendant had sexually-explicit online communications with a detective, posing as a 14-year-old, the detective researched defendant’s criminal history, which included convictions for public lewdness and disorderly conduct, obtained a warrant, and searched defendant’s home. Finding child pornography on a computer, police obtained a second warrant and discovered 3,366 images of child pornography, 95 emails sent from the computer with child pornography attachments, and 54 emails received with child pornography attachments. A district judge denied defendant's motion to suppress the fruits of the search of his home computer. Defendant pled guilty to unlawful transportation of child pornography, 18 U.S.C. 2252A(a)(1) and was sentenced to 10 years in prison. The First Circuit affirmed denial of the motion, rejecting arguments that: the warrant allowed a search that was overbroad given the narrow scope of probable cause; the computer search unlawfully exceeded the broad scope of the warrant; and the plain-view and good-faith exceptions did not apply.