State v. Ball, 53 A.3d 603

Ball was convicted of possessing child sexual abuse images after a bench trial based on stipulated facts.
Ball challenged the denial of his motion to suppress evidence obtained from a search of his home computer.
Police linked Ball to child pornography via a 2009 investigation involving a vehicle with license plate AJ-WINGS and communications with a man named Johnston.
A warrant was issued and executed August 4, 2009, permitting search of Ball’s home, computer, and cell phone for child-pornography evidence.
The search yielded four images and two videos of minors, plus emails referencing sexual activity involving a female of unknown age and a man named “Bob.”
The court analyzed whether the affidavit supported probable cause under a totality-of-the-circumstances standard and affirmed the district court’s probable-cause determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the affidavit establish probable cause linking Ball’s computer to child pornography?	Ball: insufficient nexus between contraband and computer.	Ball: lack of sufficient facts tying child pornography to Ball’s computer.	Yes; affidavit had substantial basis for probable cause.

State v. Ward, 163 N.H. 156 (2012) (probable-cause review and nexus standards for warrants)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances standard)
United States v. Leon, 468 U.S. 897 (1984) (special-needs warrant well-settled nexus analysis and deference)
State v. Fish, 142 N.H. 524 (1994) (probable-cause review and common-sense nexus)
State v. Silvestri, 136 N.H. 522 (1992) (insufficient nexus where only residence number linked to drug buy)
United States v. Jacobson, 466 U.S. 109 (1984) (judicial notice on information sources; limits on corroboration)
United States v. Hodson, 543 F.3d 286 (6th Cir. 2008) (cross-jurisdictional views on relevance of molestation evidence)
United States v. Colbert, 605 F.3d 573 (8th Cir. 2010) (reliance on officer’s expertise requires particularized facts)