Skip to content
Name: United States v. Needham
Case #: 12-50097
Court: US Court of Appeals
District 9 Cir
Opinion Date: 06/14/2013

Suppression motion was properly denied where officers reasonably relied on warrant allowing a search for pornography because defendant was suspected of child molestation. Orange County Police obtained a warrant to search Needham’s residence for evidence of child molestation. The warrant permitted a search of the home for child pornography because, in the opinion of the requesting officer, individuals who have a sexual interest in children often possess child pornography. While conducting the search, officers found images and videos of child pornography on an iPod at the residence. Needham moved to suppress the evidence based on a lack of probable cause to suspect that he possessed child pornography. The district court found that the “good faith” exception applied because the searching officer reasonably relied on the warrant. The appellate court affirmed. Although the officers in this case relied on a warrant predicated on the bare inference that those who molest children are likely to possess child pornography, which alone is not sufficient to establish probable cause, the search was executed in objectively reasonable reliance on the warrant.