United States v. Jobe, No. 18-50204 (9th Cir. 2019)
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The Ninth Circuit reversed the district court's order granting defendant's motion to suppress evidence found on a laptop seized under a State of California warrant and searched under a federal warrant. The panel held that, although there was insufficient probable cause to seize the laptop, the special agent's affidavit supporting the state warrant contained sufficient information to render his reliance on the warrant reasonable.
The panel also held that, even assuming that the 21-day delay between the seizure of the laptop pursuant to the state warrant and the search of the laptop pursuant to the federal warrant was unreasonable, suppression was not warranted where the agent's delay did not evince negligence, let alone deliberate and culpable misconduct. In this case, the agent's good faith efforts complied with the Warrant Clause of the Fourth Amendment and there was no indication that he believed he was depriving defendant of a legitimate possessory interest.
Court Description: Criminal Law. The panel reversed the district court’s order suppressing evidence found on a laptop that was seized pursuant to a State of California warrant and searched pursuant to a federal warrant. The panel accepted that there was insufficient probable cause to seize the laptop, but held that a DHS special agent’s affidavit supporting the state warrant contained sufficient information to render his reliance on the state warrant to seize the laptop reasonable. The panel held that even assuming that the 21-day delay between the seizure of the laptop pursuant to the state warrant and the search of the laptop pursuant to the federal warrant was unreasonable, suppression is not warranted. The panel explained that the delay does not evince negligence on the part of the special agent, let alone deliberate and culpable misconduct; that the record does not suggest recurring or systemic negligence; that the special agent’s good-faith efforts to comply with the Warrant Clause of the Fourth Amendment indicate that his conduct was not “sufficiently culpable that such deterrence is worth the price paid by the justice system”; and that there is no indication that the special agent believed he was depriving the defendant of a legitimate possessory interest. UNITED STATES V. JOBE 3
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