United States v. Meals, No. 20-40752 (5th Cir. 2021)Annotate this Case
The Fifth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of sexually explicit Facebook chats with an underage minor on the ground that Facebook and NCMEC are government agents. The court concluded that defendant failed to carry his burden of showing that Facebook is a government agent or instrument, and thus the private search doctrine applies. The court also concluded that later investigative techniques employed by NCMEC and government officials did not impermissibly expand the scope of the original search.