United States v. Aigbekaen, No. 17-4109 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed defendant's conviction for sex trafficking and related crimes, holding that the warrantless forensic searches of defendant's digital devices did not violate his Fourth Amendment rights.
Where a search at the border is so intrusive as to require some level of individualized suspicion, the object of that suspicion must bear some nexus to the purposes of the border search exception in order for the exception to apply. The court agreed with defendant that the border search exception did not extend to the challenged searches, because no such nexus existed here. However, the court held that the good faith exception to the exclusionary rule barred suppression. In this case, law enforcement relied on an established and uniform body of precedent allowing warrantless border searches of digital devices at the time of the search.