United States v. William Meyer, 19 F.4th 1028

Federal agents investigating “Operation Dark Room” linked William Meyer to livestreamed child sexual abuse in the Philippines and learned he had paid and stayed with perpetrators and victims.
Two agents visited Meyer, spoke with him in their car, and he admitted using a computer and cellphone to contact the abusers and offered to turn over devices later to “check [his] email and stuff.”
Meyer then declined immediate inspection, said his house was “a mess” and went inside alone after the agents requested to accompany him. Agents feared he would destroy evidence.
An agent contacted a prosecutor, was advised exigent circumstances existed, then the agents reknocked, entered without a warrant, and seized two computers, a cellphone, and a hard drive; one agent later obtained a warrant.
The devices contained extensive child pornography and communications; the district court denied Meyer’s suppression motion, he pleaded guilty to sexual exploitation of children, and received a 30-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause to search home/devices	No fair probability evidence would be found in home/devices	Agents had multiple incriminating facts linking Meyer to abuse and his devices	Probable cause existed; officers reasonably inferred involvement and nexus to devices
Exigent circumstances to justify warrantless entry	No imminent risk of evidence destruction	Meyer’s statements (need to check email, clean house, go inside alone) created a real risk of imminent destruction	Exigency existed; officers reasonably believed evidence would be imminently destroyed
Whether agents created exigency (Kentucky v. King exception)	Agents’ comments about destroying evidence and returning later manufactured the exigency	Officers employed lawful knock-and-talk and did not threaten Fourth Amendment violations; Meyer’s own conduct created exigency	Agents did not create exigency; their questions were legitimate and the exigency preexisted their remarks
Sentencing procedural error (district court’s comment on downward variance)	Court’s statement that Meyer had “to persuade” for a downward variance was erroneous and requires remand	Any error was forfeited and, even if plain, was harmless because court considered §3553(a) factors	No remand; any error did not affect substantial rights and was harmless

Brigham City v. Stuart, 547 U.S. 398 (2006) (warrant generally required to enter home absent exigency)
Kentucky v. King, 563 U.S. 452 (2011) (exigency exception unavailable if police created exigency by violating Fourth Amendment)
United States v. Ramirez, 676 F.3d 755 (8th Cir. 2012) (exigent-circumstances test requires reasonable basis to believe evidence will be destroyed)
Kaley v. United States, 571 U.S. 320 (2014) (probable cause is a low bar; requires fair probability of evidence)
Kleinholz v. United States, 339 F.3d 674 (8th Cir. 2003) (probable cause standard explained)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (officers need not accept innocent explanations when assessing probable cause)
Riley v. California, 573 U.S. 373 (2014) (recognizing the special privacy interests in digital devices and the risk of deletion)
United States v. Pirani, 406 F.3d 543 (8th Cir. 2005) (plain-error standard for forfeited sentencing claims)
Gall v. United States, 552 U.S. 38 (2007) (appellate review standard for sentencing and consideration of §3553(a) factors)