United States v. Chiu, No. 21-1120 (1st Cir. 2022)
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The First Circuit affirmed Defendant's convictions for receipt and possession of child pornography, holding that the district court did not err in denying Defendant's pre-trial motion to suppress evidence obtained pursuant to a search warrant and did not abuse its discretion in excluding certain text-message evidence as inadmissible hearsay.
On appeal, Defendant argued that the district court erred in denying his motion to suppress because the affidavit filed in support of the search warrant failed sufficiently to describe ether pornographic images to be found and that the court erred in excluding from his trial the text message evidence at issue. The First Circuit affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) the district court did not err in barring the text messages from Defendant's trial.
The court issued a subsequent related opinion or order on June 16, 2022.
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