United States v. Doyle
2011 U.S. App. LEXIS 10361
| 4th Cir. | 2011Background
- In 2004, Lee County Sheriff's deputies searched Doyle's home under a warrant for possession of child pornography; Doyle's computer yielded images.
- Doyle was later indicted in 2007 for receipt and possession of child pornography; a superseding indictment added three counts of mailing child pornography.
- Doyle moved to suppress in August 2007, arguing lack of probable cause and stale evidence; a suppression hearing followed in September 2007.
- Warrant application was signed by Captain Scott but drafted by Lt. Rouse; Scott did not participate in the investigation, and Rouse gave an unsworn summary to the magistrate.
- Informant Jones and interviews conducted by Rouse purportedly supported probable cause; however, no victim claimed seeing pornography, and timing of alleged acts was unclear.
- The magistrate recommended suppression; the district court denied suppression and held good faith applied; Doyle was convicted at trial; Fourth Circuit reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do affidavit inaccuracies defeat good faith? | Doyle argues inaccuracies destroy Leon immunity. | United States contends minor errors do not defeat Leon. | Inaccuracies alone do not defeat good faith; other deficiencies persist. |
| Did the magistrate wholly abandon neutrality (Lo-Ji Sales)? | Doyle asserts rubber-stamp magistrate violated neutrality. | United States contends magistrate remained neutral despite noncontemporaneous drafting. | No abandonment of neutral role; not dispositive for Leon. |
| Was the affidavit so lacking as to render reliance unreasonable under Leon's third exception? | Doyle contends the affidavit lacked indicia of probable cause for child pornography. | United States argues totality of information supports probable cause. | Yes, the deficiencies were so great as to render reliance unreasonable; Leon exception not controlling. |
| Was there a valid nexus and timely information linking Doyle to child pornography at his residence? | Doyle asserts no clear nexus or timing for probable cause. | United States argues inferences from item type and location support nexus. | Probable cause lacking due to vague timing and uncertain linkage to residence. |
Key Cases Cited
- United States v. Leon, 468 U.S. 897 (Supreme Court 1984) (establishes good faith exception to exclusionary rule)
- United States v. DeQuasie, 373 F.3d 509 (4th Cir.2004) (outline Leon exceptions and good faith analysis)
- United States v. Andrews, 577 F.3d 231 (4th Cir.2009) (rubber stamp and good faith discussion)
- United States v. Wilhelm, 80 F.3d 116 (4th Cir.1996) (bare bones affidavit concept in Leon context)
- Lo-Ji Sales, Inc. v. New York, 442 U.S. 319 (Supreme Court 1979) (magistrate's neutrality and open-ended warrants)
- Rugendorf v. United States, 376 U.S. 528 (Supreme Court 1964) (informant inaccuracies and personal knowledge limits)
- Zurcher v. Stanford Daily, 436 U.S. 547 (Supreme Court 1978) (nexus requirements in residential searches)
- Gates v. Illinois, 462 U.S. 213 (Supreme Court 1983) (reasonable belief and totality of circumstances in probable cause)