United States v. Jones, No. 20-3009 (2d Cir. 2022)
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Defendant was indicted for knowingly producing child pornography in violation of federal law. He moved to suppress evidence gathered from his electronic devices, arguing that the government’s search warrants lacked probable cause and therefore violated his Fourth Amendment rights. The district court denied the motion. Defendant then pleaded guilty but reserved the right to appeal the district court’s decision on his motion to suppress.
The Second Circuit affirmed the district court’s judgment explained that it disagrees with the district court that Defendant’s prior guilty plea to an earlier charge in Tennessee state court precludes him from challenging the search warrants in this case. But the court agreed that even assuming arguendo that the warrants are defective, the good-faith exception to the exclusionary rule applies.
The court explained that there was at least arguable probable cause for the Tennessee Warrants, therefore, the Detective acted based on an “‘objectively reasonable good-faith belief’ that [his] conduct [was] lawful.” The court further wrote that the affidavits at issue here are not so devoid of factual support because they detail allegations from State Victim 1’s mother that support the common-sense inference that her daughter told her that Defendant took nude photographs of her.
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