United States v. Farlow, 681 F.3d 15

Farlow pled guilty to one count of Unlawful Transportation of Child Pornography, conditioned on appealing the suppression ruling.
An AOL-Chat investigation involved a user posing as a minor, leading to discovery of Farlow’s possible crimes and identifying his Maine residence.
Maine state warrant authorized a broad search of Farlow’s home for computers and data evidencing the NY crimes of disseminating indecent materials and endangering a child.
Massachusetts/ Maine police conducted the April 23, 2007 search; a gallery view of the computer revealed child pornography, triggering a second warrant stop.
A federal indictment followed in 2009; suppression motion was denied by magistrate and district court; this appeal challenges the denial.
The First Circuit upheld the district court, affirming the denial of suppression and preserving the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause supported warrant?	Farlow: only bodybuilder image justified warrant.	Farlow: broader NY crimes not probable.	Probable cause supported broad search for NY-crime evidence.
Search within warrant scope?	Search too broad; hash-based limit needed.	Gallery-view exceeded scope; hash search preferable.	Search within warrant; broad but within authorized scope; hash not required.
Plain-view/good-faith exceptions apply?	Exceptions save unlawful aspects.	Exceptions could salvage warrant/search.	Not implicated; warrant/ search valid; exceptions unnecessary.
Remand for evidentiary hearing?	Hearing needed to probe warrant validity.	Hearing necessary to assess propriety.	No abuse of discretion; no material facts in dispute; no remand.

In re Crespo-Ríos, 645 F.3d 37 (1st Cir. 2011) (broad digital searches permitted; files highly manipulable)
United States v. Upham, 168 F.3d 532 (1st Cir. 1999) (particularity requires seizure scope to be defined)
United States v. Panitz, 907 F.2d 1267 (1st Cir. 1990) (denying evidentiary hearings where no material facts disputed)