Bradley v. State
2012 Del. LEXIS 475
| Del. | 2012Background
- Bradley was convicted of multiple counts of Rape in the First Degree, Assault in the Second Degree, and Sexual Exploitation of a Child, and sentenced to mandatory life terms and additional years.
- Video evidence Bradley made showed sexual assaults against children, largely his patients, collected during a search of BayBees Pediatrics.
- A December 15, 2009 search warrant authorized seizure of medical files (paper and digital) and video/photographs of BayBees Pediatrics premises.
- Bradley challenged the suppression ruling, arguing the affidavit lacked probable cause to search a white outbuilding and to seize electronic formats or files related to the crimes.
- Police found four buildings on the property (A: main; B: white outbuilding; C: white garage; D: tan shed) and seized devices and files across Buildings A, B, and D.
- Detective Spillan opened a deleted thumb-drive file during a search and obtained a second warrant to search digital media for further evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrant affidavit established probable cause to search the outbuilding for patient files | Bradley: outbuilding lacked plausible link to patient files relevant to crimes | Bradley: insufficient factual basis to locate files in white outbuilding or digital format | Probable cause satisfied; outbuilding reasonably linked to medical files |
| Whether patient files could reasonably be found in electronic format | Bradley: no basis to search electronic patient files | Bradley: electronic records likely exist and were described in affidavit | Probable cause supports searching electronic medical files |
| Whether police exceeded the warrant's scope by searching all buildings on the property | Bradley: search limited to specified buildings; overbroad sweep | Bradley: Building B reasonably identified as the outbuilding; others immaterial | Search of Building B proper; scope reasonable; other buildings non-prejudicial |
| Whether seizure of computers and digital devices was within the warrant's scope | Bradley: devices unrelated to patient files seized; overreach | Bradley: devices reasonably contain patient files or related evidence | Devices reasonably could contain patient files; seizure appropriate |
| Whether Detective Spillan's opening of a deleted thumb-drive file was proper | Bradley: opened file potentially outside scope of the warrant | Bradley: file likely linked to crimes described in affidavit | Opening the file reasonable; immediately halted and sought new warrant when scope appeared to exceed |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause requires totality of circumstances; reasonable belief evidence will be found)
- Maryland v. Garrison, 480 U.S. 79 (1987) (limits on scope of warrants and particularity of description)
- Sisson v. State, 903 A.2d 288 (Del. 2006) (Delaware standard for suppression; corroboration of affidavits)
- Fink v. State, 817 A.2d 781 (Del. 2003) (Delaware approach to warrant adequacy and probable cause)
- LeGrande v. State, 947 A.2d 1103 (Del. 2008) (context for probable cause and search doctrine)
- Giberson, 527 F.3d 882 (9th Cir. 2008) (modern technology and flexibility in interpreting search warrants)