United States v. Ringland, No. 19-2331 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed defendant's conviction of receipt of child pornography and the denial of defendant's motion to suppress. In this case, law enforcement officers seized and searched defendant's devices under authorized warrants based on information furnished by Google, Inc. and the National Center for Missing and Exploited Children (NCMEC).
The court held that the district court did not err when it found that Google's search of defendant's email accounts constituted a private search. In this case, Google did not act as a government agent because it scanned its users' emails volitionally and out of its own private business interests. Furthermore, Google did not become a government agent merely because it had a mutual interest in eradicating child pornography from its platform. Therefore, Google's continued actions in its own interest and the government's continued receipt of the reports does not give rise to some form of agency. Finally, the court held that because the investigator searched only the same files that Google searched, the government did not expand the search beyond Google's private party search.
Court Description: [Williams, District Judge, Author, with Colloton and Benton, Circuit Judges] Criminal Case - Suppression. After Google sent CyberTipline reports to the National Center for Missing and Exploited Children of child pornography files found on Ringland's emails accounts, NCMEC forwarded the reports to the Nebraska State Police, who obtained a warrant to search Ringland's accounts and to track his cell phone. Ringland was arrested for receiving child pornography and moved to suppress the evidence from the evidence obtained by Google as unlawful warrantless searches. The district court did not err in finding Google's search of the email accounts constituted a private search. Google did not act as a government agent by scanning the user's emails; as it had its own private business interest even if it had a mutual interest with a government interest; a reporting requirement does not transform Google into a government agent for Fourth Amendment purposes. Google's continued searches were independent of government involvement. Because the inspector searched only the files Google had searched, the government did not expand the search beyond Google's private party search.
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.