United States v. Matthew O'Dell, 766 F.3d 870

Matthew O’Dell, a YMCA camp supervisor, posed online as a girl named “Hannah,” arranged meetings with teenage boys, and engaged in sexual activity with them after meeting under that pretext. A victim reported attempted sexual abuse to Springfield police.
Detective Reece prepared an affidavit summarizing the victim T.H.’s statement and related reports from a County Children’s Division employee (Renee Wehmeier) who relayed similar reports from three other families, including a youth called “Dillion.”
The affidavit recounted that O’Dell used phones to impersonate “Hannah,” had multiple cell phones and computers, lived and kept personal belongings (including a computer) in a room at Camp Wakonda, and had been fired but left items in the room.
A Lawrence County judge issued a warrant to search O’Dell’s camp room for electronic media and images; officers executed the warrant and seized evidence.
O’Dell moved to suppress the camp-room evidence, arguing the affidavit relied on unidentified sources without demonstrated reliability and that unverified assertions should be excised; magistrate and district court denied suppression and Franks hearing requests.
O’Dell pleaded guilty subject to preserving the right to appeal the suppression denial; he appealed to the Eighth Circuit challenging probable cause for the warrant.

Issue	O’Dell’s Argument	Government’s Argument	Held
Whether affidavit supplied probable cause for warrant to search O’Dell’s camp room	Affidavit relied mainly on two unidentified juveniles (T.H., Dillion) without shown reliability; unverified, easily-checkable facts should have been confirmed and excised, leaving no probable cause	Affidavit contained statements from identified victim(s), corroboration from a Children’s Division source, and independent investigative corroboration (employment, items left in room) that establish probable cause	Affidavit provided a substantial basis for probable cause; search warrant valid and suppression properly denied

United States v. Allen, 705 F.3d 367 (8th Cir.) (standard of review for suppression rulings)
United States v. Solomon, 432 F.3d 824 (8th Cir.) (magistrate’s probable-cause determination given great deference; four-corners rule)
United States v. Williams, 10 F.3d 590 (8th Cir.) (informant reliability—track record or independent corroboration)
United States v. Keys, 721 F.3d 512 (8th Cir.) (corroboration of informant information can establish informant reliability)
United States v. Wallace, 550 F.3d 729 (8th Cir.) (law enforcement may rely on information supplied by a crime victim absent indications of unreliability)
United States v. Stevens, 530 F.3d 714 (8th Cir.) (known informants carry more weight than anonymous informants)
Franks v. Delaware, 438 U.S. 154 (U.S.) (standard for challenging an affidavit’s veracity to obtain an evidentiary hearing)