United States v. Taylor, No. 17-14915 (11th Cir. 2019)
Annotate this Case
The Eleventh Circuit affirmed defendants' convictions for child pornography related charges, holding that evidence discovered under a Network Investigative Technique (NIT) warrant need not be suppressed. The court held that the magistrate judge's actions exceeded Federal Rule of Criminal Procedure 41(b) and her statutorily prescribed authority under the Federal Magistrates Act, and thus the warrant was void ab initio. However, the court held that, because the exclusionary rule is concerned solely with deterring culpable police misconduct—and not at all with regulating magistrate judges' actions—void and voidable warrants should be treated no differently. Therefore, the court held that an officer's reasonable reliance on the former, like the latter, can provide the basis for applying the good faith exception.
The court also held that, even if the good faith exception can apply when an officer relies on a void warrant, the good faith exception was applicable in this case where the officers' warrant application adequately disclosed the nature of the technology at issue and the scope of the intended search, and the officers reasonably relied on the magistrate judge's determination that the search was permissible.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.