United States v. Houston
2012 U.S. App. LEXIS 596
| 8th Cir. | 2012Background
- Houston pled guilty to possession of child pornography (18 U.S.C. § 2252A(a)(5)(B), 2256(8)(A)).
- Investigative trail began with E.L.’s mother, posing as her daughter, eliciting incriminating admissions and revealing computer history and a disk Houston took to Wisconsin.
- South Dakota warrant #1 seized Houston’s computers for Wisconsin molestation evidence; admissible under officers’ good-faith reliance.
- Wisconsin warrant #2 sought evidence of first-degree sexual assault and/or child pornography based on an affidavit linking molestation to possession of child pornography; several hundred images found.
- Houston moved to suppress the computer evidence; district court denied, applying Leon good-faith exception; Houston pleaded guilty but preserved suppression challenge.
- Court affirms, finding Shawback’s reliance on warrant #2, and thus the Leon good-faith exception, were reasonable in light of the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Warrant #2 lacked probable cause for searching South Dakota computers. | Houston argues Warrant #2 is facially deficient; no probable cause for Wisconsin-related search. | USA contends the nexus between molestation and possession of child pornography and Shawback’s affidavit supported probable cause. | No; good-faith exception applied; warrant not so facially deficient as to render belief unreasonable. |
| Whether the Leon good-faith exception applies given Wisconsin-limited warrant scope. | Houston asserts exclusion should apply because warrant limited to Wisconsin offenses. | USA argues officers acted reasonably relying on warrant and magistrate’s determination. | Yes; good-faith exception applies; suppression not warranted. |
Key Cases Cited
- United States v. Colbert, 605 F.3d 573 (8th Cir.2010) (recognizes nexus between molestation and possession of child pornography and admissibility under good faith)
- United States v. Perry, 531 F.3d 662 (8th Cir.2008) (reiterates standard for de novo review of probable cause and Leon applicability)
- United States v. Proell, 485 F.3d 427 (8th Cir.2007) (good-faith inquiry framework and exceptions)
- United States v. Leon, 468 U.S. 897 (1984) (establishes good-faith exception to exclusionary rule)
- United States v. Puckett, 466 F.3d 626 (8th Cir.2006) (defines objective reasonableness standard for good-faith reliance)
- United States v. Hill, 55 F.3d 479 (9th Cir.1995) (non-exclusive citation supports broad interpretation of warrant authority)
- United States v. Matya, 541 F.2d 741 (8th Cir.1976) (assists in understanding intraterritorial reach of warrants)