United States v. Snell, 3:24-cr-00103

David A. Snell was investigated and indicted for production, distribution, and possession of child pornography, as well as coercion and enticement of minors.
Law enforcement, using undercover operations and administrative summonses to online platforms (including Reddit and Altafiber), identified Snell as linked to multiple accounts suspected of child exploitation.
Information acquired from these third-party platforms was limited to basic subscriber data (usernames, email addresses, and IP addresses), not substantive message contents.
Substantive communications were accessed independently by law enforcement (via undercover operations or consent to search a victim’s devices) or were obtained via tips to the National Center for Missing and Exploited Children (NCMEC), after third-party review.
Snell filed a motion to suppress, arguing that the administrative summonses violated the Fourth Amendment’s warrant requirement by soliciting private information.
The court set a briefing schedule and considered the parties’ arguments without holding a suppression hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether administrative summonses for subscriber info violate Fourth Amendment	Admin summonses only sought basic info; not a protected privacy interest	Summonses were overbroad; violated expectation of privacy	Summonses did not violate Fourth Amendment
Whether evidence from administrative summonses must be suppressed	Basic subscriber info is not protected under Fourth Amendment	All evidence from summonses/warrants should be suppressed	Suppression is not warranted; administrative summonses are lawful
Whether Snell had a reasonable expectation of privacy in subscriber info	No reasonable expectation; info is shared with third parties	Reasonable expectation in identity info provided to platforms	No reasonable expectation in subscriber info
Whether review of contents found by third parties or with victim consent requires warrant	Substances obtained independently/by consent or after third-party review	Content was wrongfully accessed without a warrant	Law enforcement acted within legal bounds; no Fourth Amendment violation

Katz v. United States, 389 U.S. 347 (application of the Fourth Amendment depends on a reasonable expectation of privacy)
Smith v. Maryland, 442 U.S. 735 (reasonable expectation of privacy standard for Fourth Amendment)
Illinois v. Gates, 462 U.S. 213 (probable cause assessment for warrants)
Wong Sun v. United States, 371 U.S. 471 (exclusionary rule for evidence from unlawful searches)
Franks v. Delaware, 438 U.S. 154 (need for warrant from neutral magistrate)
United States v. Miller, 425 U.S. 435 (no expectation of privacy in information given to third parties)
United States v. Jacobsen, 466 U.S. 109 (no warrant needed when third parties expose material to law enforcement)
Kyllo v. United States, 533 U.S. 27 (Fourth Amendment adapts to technological change)
Carpenter v. United States, 585 U.S. 296 (Fourth Amendment requires warrant for cell-site location data)
United States v. Warshak, 631 F.3d 266 (reasonable expectation of privacy in private correspondence)