United States v. Thomas, No. 17-4523 (4th Cir. 2018)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of child pornography from a cell phone. The court held that, while the warrant affidavit alone did not establish probable cause, the evidence was admissible under the good faith exception to the exclusionary rule articulated in United States v. Leon, 468 U.S. 897 (1984). Under the circumstances, the officer had a reasonable basis to believe that there was probable cause to search the phone.