United States v. Charles Brian O'Neill, 94 F.4th 531

Charles O’Neill’s wife and son reported to police that they found hundreds of images of nude or partially nude minor boys on O’Neill's devices.
Police obtained a search warrant for O’Neill’s home based on affidavits referencing these images and generic characteristics of child pornography offenders, including a mistaken statement about use of a peer-to-peer (P2P) pornography network.
After the home search, O’Neill’s son discovered further items (computer, digital media, sex toys, children’s clothing) in a locked room at a barn owned by O’Neill, prompting law enforcement to obtain another warrant for that location—using a similar, flawed affidavit.
Evidence from both the house and barn revealed large caches of suspected child pornography, leading to federal charges for sexual exploitation of a minor and receipt of child pornography.
O’Neill moved to suppress the evidence, arguing the affidavits lacked probable cause and contained recklessly false statements; the district court denied the motions, applying the good-faith exception.
On appeal, O’Neill challenged only the suppression ruling related to the barn warrant.

Issue	O’Neill’s Argument	United States’ Argument	Held
Did the affidavit contain reckless or intentional falsehoods, barring good-faith reliance?	The affidavit’s claim that O’Neill used a P2P network was recklessly false and material; copying boilerplate is no excuse.	Officers' inclusion of the P2P statement was a negligent copy-paste error, not reckless or knowing falsehood.	No reckless disregard; error was negligent. Good-faith exception applies.
Was the affidavit so conclusory (bare-bones) that good-faith reliance was unreasonable?	The affidavit only established possession of nude child photos, which is not child pornography; thus, no probable cause.	The affidavit referenced a massive collection of images and suspicious related items, making reliance objectively reasonable.	Not bare-bones; affidavit contained sufficient factual material for good-faith reliance.
Was the warrant facially deficient or overbroad?	The warrant lacked specificity and thus could not be reasonably presumed valid.	Warrant described suspected crimes, location, and items to be seized with particularity.	Warrant was not facially deficient; good-faith reliance justified.
Did O’Neill preserve all issues for appeal under his plea agreement?	Argued for broad reservation of right to appeal suppressions from both locations.	Plea reserved only the barn suppression denial for appeal.	Only issues related to barn warrant suppression preserved.

United States v. Leon, 468 U.S. 897 (defined and applied the good-faith exception to the exclusionary rule)
Franks v. Delaware, 438 U.S. 154 (sets standard for excising deliberate or reckless falsehoods from affidavits)
New York v. Ferber, 458 U.S. 747 (distinction between nude images and child pornography under First Amendment)
Osborne v. Ohio, 495 U.S. 103 (reiterates that mere nudity is protected absent lewdness)
Illinois v. Gates, 462 U.S. 213 (standard for probable cause in warrant applications)
Davis v. United States, 564 U.S. 229 (purpose and limits of exclusionary rule)