United States v. Augard, No. 19-1507 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to dismiss evidence uncovered when police searched the home he shared with his parents. Defendant pleaded guilty to two counts of production of child pornography and one count of possession of child pornography.
The court held that, although the warrant lacked probable cause, it fell within the Leon good faith exception to the exclusionary rule. In this case, considering the specific nature of the crimes being investigated, the evidence supporting the warrant application was not so stale as to render the officer’s reliance on the warrant entirely unreasonable. Furthermore, the type of evidence sought establishes the warrant was not so stale that the officer's reliance was entirely unreasonable; there was a sufficient nexus connecting the evidence to the house; and defendant's remaining challenges were rejected.
Court Description: [Erickson, Author, with Colloton and Shepherd, Circuit Judges] Criminal case - Criminal law. Evidence seized from defendant's home under a state court search warrant was admissible under the Leon good-faith exception. [ March 30, 2020 ]
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