United States v. O'Dell, No. 13-2381 (8th Cir. 2014)
Annotate this CaseDefendant plead guilty to one count of sexual exploitation of children and appealed the denial of his motion to suppress evidence seized under a search warrant from his room at the YMCA camp. The court agreed with the district court that the information contained in the affidavit provided sufficient probable cause to issue the warrant to search defendant's room at camp where, according to the affidavit, one of the alleged victims identified himself to officers and voluntarily provided a detailed statement regarding how defendant approached him and the attempted sexual abuse; the identity of the victims were known to law enforcement at the time the affidavit was prepared; the affidavit also included similar information that a detective had received from a County Children's Division employee; and some of the information provided by the victims was corroborated by the detective's independent investigation. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law. The affidavits submitted in support of the search warrant application established probable cause to search defendant's temporary residence; while the affidavit relied on information supplied by minor victims who were identified only by initials, the police knew the identity of the victims and had corroborated details of their statements; additionally, the victims' separate statements were consistent and the receipt of consistent information from two separate sources is a form of corroboration.
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