United States v. Patten, No. 11-2268 (8th Cir. 2011)
Annotate this CaseDefendant pleaded guilty to one count of sexual exploitation and attempted sexual exploitation of a minor, and two counts of possession and attempted possession of child pornography. Defendant appealed the district court's denial of his motion to suppress and his 480-month term of imprisonment. The court held that the district court properly denied defendant's motion to suppress based on the good faith exception, regardless of whether the affidavit at issue was sufficient to establish probable cause. The court also held that defendant's challenge to the reasonableness of his sentence was barred by the appeal waiver contained in the plea agreement. The court further held that defendant's sentence did not violate the Eighth Amendment. Accordingly, the judgment was affirmed.
Court Description: Criminal case - Criminal law and sentencing. Based on all of the factors in the case, the district court did not err in finding the evidence seized during a search was admissible under the Leon good-faith exception; challenge to the substantive reasonable of his sentence was barred by defendant's appeal waiver; Eighth Amendment challenge to sentence was not waived, but the sentence, which was within the statutory range, did not violate the Eighth Amendment.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.