Manzione v. State, 312 Ga. App. 638

Manzione was convicted on 20 counts of sexual exploitation of children after a bench trial following a search of his residence and electronic devices.
The search warrant was based on an affidavit summarizing information from NCMEC about images reported by Yahoo! Groups and traced to an IP address.
Yahoo! identified Charter Communications as the ISP and provided subscriber information linking the account to Manzione, including his address.
GBI agents used that information to confirm identity and conducted surveillance before seeking the warrant.
Manzione moved to suppress the images; the trial court denied, and he appealed challenging the affidavit’s reliance on hearsay and NCMEC’s role.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause based on hearsay via NCMEC/Yahoo!	Manzione argues the affidavit rests on inadmissible hearsay and an unverified Yahoo! report via NCMEC.	Manzione contends the Yahoo!/NCMEC reporting is unreliable and requires independent verification.	Affidavit supported probable cause; Yahoo!/NCMEC report afforded credibility and totality-of-circumstances supported seizure.
Independence of NCMEC verification	NCMEC’s disclaimer shows it did not investigate or vouch for accuracy.	Even if not independently verified, credibility of the reporting entity is preserved and does not defeat probable cause.	Reliability given to NCMEC’s role is permissible; no independent verification required to establish probable cause.

James v. State, 312 Ga. App. 130 (2011) (Yahoo/NCMEC reporting treated as credible; corroboration not required for probable cause)
Whitten v. State, 174 Ga. App. 867 (1985) (concerns credibility of informants and preferred status of concerned citizens)
Penny v. State, 248 Ga. App. 772 (2001) (built-in credibility for identified concerned citizens or victims)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause assessed under totality-of-circumstances)