United States v. Morgan Chase Woods
684 F.3d 1045
| 11th Cir. | 2012Background
- Woods, a Navy Arabic linguist, faced one count of receipt and two counts of possession of child pornography.
- Ex-wife found child pornography on Woods’s HP computer; NCIS recovered images and forensics linked Woods to material.
- May 12, 2009 interview: Woods consented after being advised of Miranda-type rights via a waiver; no coercion or arrest; Woods cooperated.
- Woods signed a permissive search consent for the home computer; DCFL/NCIS conducted forensic analysis identifying child pornography.
- July 16, 2009 interview: Woods again waived rights after being read the waiver; a written statement was prepared with Woods’ input.
- Indictment followed in August 2009 with three counts; Woods moved to suppress statements and challenging vagueness; magistrate recommended denial of suppression; district court adopted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Miranda waiver adequately conveyed rights | Woods argues waiver was confusing and misleading | Woods contends warnings misstate right to a particular type of counsel | Waivers adequately conveyed rights; not unconstitutional as applied |
| Vagueness/overbreadth of §2252A(a)(2) and (a)(5)(B) | Woods claims statutes are vague/overbroad for mere viewing | N/A (Woods challenges statutes broadly) | Statutes not vague or overbroad as applied or facially; viewing and possession contemplated |
| Multiplicity of charges for receipt and possession | Bobb dictates potential multiplicity; storage times overlap | Counts based on different time periods and computers; bill of particulars cures | Not multiplicitous; three counts based on distinct facts/timeframes/computers |
| Admission of NCMEC-match testimony (not hearsay) | Evidence about matches to NCMEC database was hearsay and unfairly prejudicial | Testimony explained forensic process, not to prove factual truth of matches | Testimony admissible as non-hearsay to explain selection process; not unfairly prejudicial |
| Admission of 414 evidence (niece molestation) and mistrial denial | Evidence showed prior molestation; probative of crime-porn interest | Prejudicial and improper under Rule 414/403 | Admissible under Rule 414 and not unduly prejudicial; mistrial denied |
Key Cases Cited
- United States v. Adams, 1 F.3d 1566 (11th Cir. 1993) (Miranda rights and the right to counsel during interrogation)
- Florida v. Powell, 570 U.S. ... (2010) (Miranda warnings need not be perfect; must convey rights reasonably)
- United States v. Bobb, 577 F.3d 1366 (11th Cir. 2009) (Receipt and possession overlap; possession as lesser-included offense of receipt)
- United States v. Pruitt, 638 F.3d 763 (11th Cir. 2011) (Clarifies meaning of 'knowingly' and 'receive' in §2252A(a)(2)})
- United States v. Williams, 553 U.S. 285 (Supreme Court 2008) (Vagueness and overbreadth framework)