People v. Manganiello
2025 NY Slip Op 03873
| N.Y. App. Div. | 2025Background
- The Oswego County Sheriff's Department received tips from Google that child sexual abuse material had been uploaded from an account linked to Spencer Manganiello.
- Police obtained a search warrant for Manganiello's person, apartment, and electronic devices. The warrant authorized officers to compel biometric unlocking of devices.
- During warrant execution, officers compelled Manganiello to unlock his phone using his fingerprint, uncovering over 100 sexually explicit videos involving children.
- Manganiello was charged with promoting and possessing a sexual performance by a child; he moved to suppress evidence, claiming a Fifth Amendment violation.
- The county court denied the motion, Manganiello pled guilty, and was sentenced to probation; he appealed, arguing his compelled fingerprint was a violation of his Fifth Amendment right against self-incrimination.
Issues
| Issue | Manganiello (Defendant) Argument | People (Prosecution) Argument | Held |
|---|---|---|---|
| Fifth Amendment – Testimonial Nature of Biometric Unlocking | Compelled biometric unlocking is testimonial and self-incriminating | Act of unlocking not testimonial; just access to physical trait | Act of unlocking was testimonial; Fifth Amendment violated |
| Fourth Amendment – Particularity of Search Warrant | Warrant lacked sufficient particularity | Warrant was specific enough | Warrant did not lack particularity |
| Suppression of Evidence | All evidence from compelled fingerprint must be suppressed | Evidence is admissible; unlocking act not testimonial | Evidence must be suppressed |
Key Cases Cited
- United States v. Hubbell, 530 U.S. 27 (2000) (distinguishes between compelled production of evidence and testimonial communication for Fifth Amendment analysis)
- Doe v. United States, 487 U.S. 201 (1988) (defining "testimonial" for self-incrimination purposes)
- United States v. Wade, 388 U.S. 218 (1967) (discusses physical evidence versus testimonial evidence distinction)
- Schmerber v. California, 384 U.S. 757 (1966) (compelled physical evidence and Fifth Amendment limits)