State v. Sawyer, 335 Conn. 29

Roommate Lawrence Lussier observed defendant Thomas Sawyer at a bedroom computer viewing a slideshow: a naked boy (about 8–9) with genitals exposed and no visible pubic hair, then a naked girl with small breasts covering her genital area; thumbnails were visible but too small to identify.
Lussier reported this to police, gave a recorded statement, and detectives prepared an affidavit including their experience and that deleted/viewed files can be recovered from computers.
A judge issued a warrant to search Sawyer’s residence and seize computers/storage; execution recovered electronics with over 400 suspected child pornography images and some videos; Sawyer admitted he "enjoyed looking at" photos/videos of prepubescent boys.
Sawyer was charged, moved to suppress the seized evidence arguing the affidavit lacked probable cause because the described photos were not lascivious, and then entered a conditional nolo contendere plea reserving the suppression claim.
The trial court denied suppression; the Connecticut Supreme Court affirmed, holding the warrant was supported by probable cause under the totality of the circumstances and declined to adopt a stricter state constitutional probable-cause standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the affidavit supplied probable cause to search for child pornography	Affidavit facts and reasonable inferences (slideshow, thumbnails, intentional viewing, officers' expertise) gave a fair probability evidence would be found	Descriptions were too brief and non-lascivious; observer lacked special expertise; no fair probability images were lascivious	Warrant supported: judge could reasonably infer substantial chance defendant possessed lascivious images under totality of circumstances
Whether Connecticut Constitution requires a "more probable than not" probable-cause standard	Existing standard (less than preponderance) should remain; no compelling reason to depart	State-level protection should require >50% probability, at least when it's unknown if a crime occurred	Court refused to adopt a higher or dual standard; upheld traditional probable-cause test (less than preponderance)

State v. Shields, 308 Conn. 678 (Conn. 2013) (probable cause requires less than preponderance; reviewdeference to issuing judge)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances test; fair probability standard)
United States v. Dost, 636 F. Supp. 828 (S.D. Cal. 1986) (formulated factors to assess "lasciviousness" of images)
United States v. Hill, 459 F.3d 966 (9th Cir. 2006) (application of Dost factors to support probable cause)
United States v. Griesbach, 540 F.3d 654 (7th Cir. 2008) (verbal description focusing on genitalia can support probable cause)
State v. Geisler, 222 Conn. 672 (Conn. 1992) (multifactor framework for determining whether state constitution affords greater protections)