United States v. Arnold D. Holland, 22-11819

Holland convicted in 2004 for receiving child pornography; released to three years supervised release in 2014 and lived at Dismas House (expelled 2015 for possessing a camera phone).
He later violated supervised-release terms (unauthorized phones, pornography) and was resentenced with a new sex-offender compliance contract restricting possession of "sexually oriented material," internet use without approval, and permitting inspections.
NCMEC/GBI cybertips traced uploads of explicit images of prepubescent boys (Dec 2017–Jan 2018) from an Instagram account tied to an email and a phone number that matched Holland’s driver’s-license number.
GBI Special Agent Bigham investigated, shared findings with Probation Officer Brewer, who reviewed Holland’s file (criminal history, psychosexual evaluation showing high risk, prior device violations) and coordinated with Bigham.
On January 14, 2019, probation officers (with Bigham on site) searched Holland’s residence, seized four unauthorized phones containing evidence; a magistrate and the district court denied Holland’s suppression motion.
Holland appealed, arguing the information was stale and that the compliance-contract term "sexually oriented material" is unconstitutionally vague; the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probation officers had reasonable suspicion to search Holland’s home based on the Instagram cybertip and other information	Holland: tip was stale (posted ~1 year earlier) and collective-knowledge doctrine inapplicable	Government: totality of circumstances + collective knowledge supported reasonable suspicion; information not stale	Court: search reasonable; collective knowledge applied; linking account phone to Holland and his history made info not stale
Whether images uploaded to Instagram qualified as violations or made the compliance term void for vagueness	Holland: images may not be "sexually oriented" and the contract term is vague	Government: whether images alone fit the term is irrelevant because other facts supported suspicion of internet use/unauthorized phones	Court: declined to decide vagueness; held the precise definition unnecessary because other violations supplied reasonable suspicion

United States v. Knights, 534 U.S. 112 (U.S. 2001) (probationer searches may be reasonable under lesser standard when conditions reduce expectation of privacy)
United States v. Carter, 566 F.3d 970 (11th Cir. 2009) (reasonableness balancing for searches of probationers)
United States v. Yuknavich, 419 F.3d 1302 (11th Cir. 2005) (particularized, objective basis and articulable facts for reasonable suspicion)
United States v. Esle, 743 F.2d 1465 (11th Cir. 1984) (collective-knowledge doctrine applies when officers communicate and coordinate)
United States v. Touset, 890 F.3d 1227 (11th Cir. 2018) (child-pornography evidence is less likely to become stale; electronic storage persists)
United States v. Harris, 526 F.3d 1334 (11th Cir. 2008) (reasonable suspicion may arise from lawful activity)