United States v. Mark Scott, 901 F.3d 842

Mark Scott placed a Craigslist ad and exchanged sexually explicit messages and photos with an undercover agent posing as a 14-year-old; Scott offered to "host" the encounter and requested sexual photos showing an erection.
Wisconsin agents arrested Scott for attempting to have sexual relations with a minor and obtained a state search warrant for his home and computers based on an affidavit describing the communications, photos, and an agent's statement that pedophiles collect child pornography.
Executing the warrant, officers found child pornography at Scott’s home; Scott moved to suppress the evidence.
The district court denied suppression, concluding the warrant was supported by probable cause; Scott pleaded guilty but reserved the right to appeal the suppression ruling.
The Seventh Circuit reviewed the issuing judge’s finding with "great deference" and affirmed the warrant’s validity without relying solely on the officer’s bare "training and experience" assertion.

Issue	Scott's Argument	Government's Argument	Held
Whether the affidavit provided probable cause to search Scott's home for child pornography	Warrant lacked nexus to home; sexual encounter planned elsewhere and possible images only on phone	Affidavit tied electronics, explicit photos, hosting offer, and typical transfer/storage practices to justify searching home/computers	Affirmed: probable cause existed; judge’s finding entitled to great deference
Whether an officer’s generic "training and experience" statement alone can establish probable cause	Such ipse dixit is insufficient and fact-free	Government relied on additional factual connections beyond the generic statement	Court rejected reliance on bare "training and experience" alone and did not rely on it here
Whether pedophilia implies possession of child pornography such that one crime justifies searching for the other	Scott: no reliable link; inference unwarranted without data	Government: sexual communications/photos support inference that child pornography may be present	Court: inferences between crimes should be data-driven; but here affidavit supplied additional factual links so probable cause supported
Standard of review for magistrate judge’s probable-cause determination	(Scott argued de novo)	Government: issuing judge’s decision merits great deference per precedent	Held: great deference applies (citing Gates); court will not perform de novo review

Illinois v. Gates, 462 U.S. 213 (establishes the totality-of-the-circumstances test and deference to magistrate probable-cause determinations)
United States v. McIntire, 516 F.3d 576 (7th Cir.) (discusses deference to issuing judge)
United States v. Lowe, 516 F.3d 580 (7th Cir.) (collection of images focused on children’s genitalia can support inference of child pornography possession)
United States v. Cordero-Rosario, 786 F.3d 64 (1st Cir.) (affidavits failing to connect conduct to possession of child pornography)
United States v. Falso, 544 F.3d 110 (2d Cir.) (insufficient nexus in affidavit to support search for child pornography)
Virgin Islands v. John, 654 F.3d 412 (3d Cir.) (rejecting weak affidavit connections)
United States v. Doyle, 650 F.3d 460 (4th Cir.) (insufficient nexus to justify search for child pornography)
United States v. Hodson, 543 F.3d 286 (6th Cir.) (affidavit deficiencies in linking crimes)
Dougherty v. City of Covina, 654 F.3d 892 (9th Cir.) (caution against relying on bare training-and-experience assertions)
United States v. Colbert, 605 F.3d 573 (8th Cir.) (holding that proof of one crime may establish probable cause to search for related offenses)
Florida v. J.L., 529 U.S. 266 (requires detail when affidavits rely on informant experience)
Florida v. Harris, 568 U.S. 237 (addresses necessity of detail to establish reliability of canine evidence)