United States v. Workman

The FBI used malware to identify and find viewers of child pornography to access illicit websites. The FBI maintained the website in the Eastern District of Virginia, but users were spread out all over the country. Finding those users could prove difficult because of geographic constraints on the FBI’s ability to obtain a warrant. Notwithstanding these constraints, the FBI obtained a warrant that led to the discovery of hundreds of viewers of child pornography. One was the defendant, who faced prosecution in the District of Colorado. In the subsequent prosecution, the district court held that the warrant was invalid and suppressed evidence resulting from the search. The Tenth Circuit reversed this ruling, finding that even when a search warrant is invalid, the resulting evidence should not be suppressed if the executing agents could reasonably rely on the warrant. Here, the Court assumed for the sake of argument that the warrant was invalid. But in the Court's view, the executing agents acted in an objectively reasonable manner. Thus, the evidence should not have been suppressed. View "United States v. Workman" on Justia Law