United States v. Taylor, No. 22-1925 (7th Cir. 2023)
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The primary source of incriminating information against Taylor was “Doe,” a woman with whom Taylor and his wife were intimately involved. Law enforcement presented a warrant application to an Indiana judge, seeking to search Taylor’s residence for evidence of child pornography and bestiality. The affidavit did not disclose that two officers involved in the investigation had been competing with Taylor for Doe’s affection. The judge signed a typed warrant that authorized the search of Taylor’s residence for evidence of child pornography; it did not mention bestiality. At a time unknown and under unknown circumstances, the lead detective apparently made handwritten alterations, adding “bestiality” to the warrant’s scope. When officers executed the altered warrant, they found substantial evidence that Taylor was producing and distributing child pornography. They found no evidence relating to bestiality. Taylor's motion to suppress and request for a Franks hearing were denied. Taylor pled guilty and was sentenced to 324 months.
The Seventh Circuit vacated. An evidentiary hearing is needed to determine whether the judge approved the alterations before the warrant's execution. Questions surrounding those alterations are relevant to the good-faith exception to the exclusionary rule so the hearing must encompass false statements and material omissions in the affidavit and law enforcement’s subjective good faith in seeking the warrant. The affidavit did not support probable cause to search for evidence of child pornography but did support probable cause to search for evidence of crimes of bestiality.
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