Bennett D. Couch v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedFebruary 15, 2024
Docket2023 SC 0237
StatusUnknown

This text of Bennett D. Couch v. Commonwealth of Kentucky (Bennett D. Couch v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Bennett D. Couch v. Commonwealth of Kentucky, (Ky. 2024).

Opinion

RENDERED: FEBRUARY 15, 2024 TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0237-MR

BENNETT D. COUCH APPELLANT

ON APPEAL FROM KENTON CIRCUIT COURT V. HONORABLE MARY K. MOLLOY, JUDGE NO. 21-CR-01440

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY CHIEF JUSTICE VANMETER

AFFIRMING

This criminal case arises from the Kenton Circuit Court’s conviction of

Bennett D. Couch due to her possession and transfer of child pornography in

violation of KRS 1 531.335 and 531.340. Couch raises two primary issues: (i)

the constitutionality of KRS 531.330’s presumption as to minority; and (ii) the

trial court’s denial of her motion to suppress the search of her apartment.

Finding no merit to Couch’s arguments, we affirm.

I. Factual and Procedural Background

In July 2021, Detective Brian Jones with the Kenton County Police

Department received a CyberTipline Report from the National Center for

1 Kentucky Revised Statutes. Missing and Exploited Children (NCMEC) that three pornographic images of

children were being circulated online. Two different district court judges

approved search warrants in this case, permitting law enforcement to search

the following for evidence of crimes associated with the possession or

distribution of child pornography: (1) Couch’s Tumblr account; (2) her

apartment; (3) her cell phones; and (4) her computers and other electronic-

storage devices located in the apartment. The police executed the search

warrants.

The CyberTipline Report originated from Tumblr, a blogging social media

website, reporting three pornographic images of children had been uploaded to

a specific Tumblr account with the username “onlynastieconfessions.” The

initial search warrant was directed at Tumblr to uncover additional information

about this account. 2 The username was associated with Couch’s email

address. The CyberTipline Report also provided the IP address from which the

child pornography was uploaded to Tumblr; it was geolocated to Fort Mitchell

in Kenton County. Upon further investigation, Det. Jones was able to identify

Couch as the subscriber for that particular IP address and resident at the

location associated with the IP address.

Det. Jones recognized the three images as having a watermark

reading “LS Studios.” LS Studios is or was a Ukrainian company that

historically created and sold online hundreds of thousands of child

2 Couch presents no argument as to the validity of this initial search warrant.

2 pornography files. In each of the affidavits for the search warrants, Det. Jones

affirmed that he had viewed the images and that they “depict[ed] a sexual

performance by a minor. All three (3) of the images depict prepubescent female

minors.”

On August 23, 2021, Det. Jones executed the next Application and

Affidavit in Support of a Search Warrant. In that affidavit, he identified the

premises at 275 Battery Court, Apartment 6, Fort Mitchell, in Kenton County,

described the building and the location of Apartment 6, including two pictures

of the building and the door. He then described the property sought:

Images and/or videos depicting sexual conduct/performance by a minor (as defined by KRS 531.300). Computers, data drives, hard drives, floppy disks, optical disks, tape disks, memory cards, USB “thumb” drives and/or any other internal or external storage devices capable of storing digital pictures or videos. Any monitors and/or peripheral equipment such as printers, digital scanning equipment, modems, routers, and connecting cables. Any computer software programs capable of storing or displaying digital pictures or videos. If the computers or other digital devices are found in a running state, the investigator may acquire evidence from the devices prior to shutting the devices off, including by means of preview software, to preserve volatile evidence. Any documentation and/or notations referring to the computer system, the contents of the computer, the use of the computer or any computer software and/or communications and all information within the above listed items including but not limited to machine readable data and all previously erased data as it relates to images and/or videos depicting sexual conduct/performance by minors. which property Affiant believes to be: ( ) stolen ( X ) property or things used as the means of committing a crime

3 ( X ) property or things in possession of a person who has intention to use it as means of committing a crime or in the possession of another to whom any person may have delivered it for purpose of concealing it or preventing its being discovered. ( X ) things which consist of evidence which tends to show that a crime has been committed or that a particular person has committed a crime. ( X ) contraband AFFIANT STATES THAT on or about July 29, 2021, the Affiant received a CyberTipline Report, Report 94392802, from the National Center for Missing and Exploited Children. The Center receives tips from internet service providers which have identified activity involving child pornography and other internet crimes against children. The report originated from Tumblr, Inc., and involves pornographic images and/or videos of children being uploaded. The Report provides that three (3) images of child pornography were uploaded to the above-described Tumblr account from the IP address 74.132.229.2. The Report contains an incident date of July 3, 2021 at 21:57:17 UTC. Affiant has viewed the three (3) images associated with the Report and can confirm that they contain matter which depict a sexual performance by a minor. All three (3) of the images depict prepubescent female minors. One of the photos contains a watermark that reads “LS-Magazine.” Based on training and experience, Affiant knows that LS Studios was a Ukrainian online subscription service and photography studio, which existed between 2001-2004, that created hundreds of thousands of images, and hundreds of videos, of young teen and prepubescent girls and sold such on the internet. During that time, the company created approximately 80 issues or collections, the title of each beginning with the company initials. The Report further identified the user of the Tumblr account as having the email address becouch11@gmail.com. Affiant confirmed through Tumblr that the reported account with email address becouch1l@gmail.com was created on July 1, 2021. The IP address 74.132.229.2 geo-locates to Fort Mitchell, Kenton County, Kentucky. Charter Communications confirmed that the IP address 74.132.229.2 has been leased to Bennett Couch at the above-described address 275 Battery Court, Apartment 6, in Fort Mitchell, Kenton County, Kentucky, beginning on July 15, 2020, up to and including July 29, 2021.

4 The e-mail address associated with the Charter Communications account is bdcouch111@gmail.com. Affiant met with management of the apartment complex who confirmed that Bennett Couch is the sole resident of the above- described apartment. Affiant reviewed the KY OL record, including the OL photo, of Bennett Couch. On or about August 17, 2021, Affiant traveled to the above-described residence and observed a person recognized as Couch exit the building and enter a vehicle registered to Bennett Couch.

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