James Maddox v. State

CourtCourt of Appeals of Georgia
DecidedJune 27, 2018
DocketA18A0659
StatusPublished

This text of James Maddox v. State (James Maddox v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Maddox v. State, (Ga. Ct. App. 2018).

Opinion

THIRD DIVISION ELLINGTON, P. J., BETHEL and GOBEIL, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

June 27, 2018

In the Court of Appeals of Georgia A18A0659. MADDOX v. THE STATE.

GOBEIL, Judge.

Following a bench trial in Cobb County Superior Court, James Maddox was

convicted of two counts of distributing child pornography and two counts of

possessing child pornography. Maddox now appeals from the denial of his motion for

a new trial, arguing that the trial court erred in admitting a written document provided

police by Maddox’s Internet service provider (“ISP”) in response to a subpoena. He

further contends that in the absence of that document, the evidence was insufficient

to convict him of distributing child pornography. Additionally, Maddox claims that

even if the subpoenaed document was admissible, the evidence failed to prove that

he distributed child pornography and the trial court therefore erred in denying his

motion for a directed verdict on the distribution charges. And Maddox also asserts that the trial court erred in denying his motion to suppress: (1) the subscriber

information obtained through an allegedly illegal subpoena served on his ISP; (2)

evidence obtained during a search of Maddox’s residence pursuant to a warrant; and

(3) incriminating statements Maddox made during his initial police interview. For

reasons explained below, we find no error and affirm.

“On appeal from a criminal conviction, the defendant is no longer entitled to

a presumption of innocence and we therefore construe the evidence in the light most

favorable to the jury’s guilty verdict.” Marriott v. State, 320 Ga. App. 58, 58 (739

SE2d 68) (2013) (citation omitted). So viewed, the record shows that this case

involves the distribution of child pornography through a peer-to-peer file sharing

program, which represents a commonly used method of obtaining and sharing child

pornography. Such programs allow the sharing of digital media and documents

between computers. One of these peer-to-peer programs, known as ARES, is

available for any member of the public to download from the Internet. When ARES

downloads, it automatically installs on the user’s desktop a folder that is identified

as “My Shared Folder.” Other ARES users are then able to access, view, and

download any document or digital media stored in the shared folder of another ARES

2 user.1 Additionally, when an ARES user downloads information from the shared

folder of another ARES computer, the items downloaded will automatically be stored

in the user’s shared folder. If a user wants to prevent downloaded items from being

accessed and downloaded by others, he or she can move those files out of the shared

folder, delete the files, disconnect his or her computer from the Internet, or uninstall

the peer-to-peer file sharing program.

Once a person has downloaded the ARES program, he or she can use it to

search for specific terms. The program will then compile a list of other ARES users

whose shared folders contain filenames that include one or more of those search

terms. The user then has the ability to download those “matching” files, which will

automatically be stored in his or her computer’s shared file folder.2

In or about May 2013, the Cobb County Police Department was investigating

the ARES peer-to-peer file sharing program to determine if anyone in Cobb County

was distributing child pornography using the ARES network. The Cobb County

1 ARES does not allow a user to see anything on another computer that is not stored in the shared folder. 2 One of the investigating officers testified that in his experience, people interested in obtaining and exchanging child pornography have chat rooms and “other areas” on the Internet where they can discuss file names. People can then run ARES searches based on this information.

3 Police Department ran on one of its secure computers a program called Round Up

ARES (“RU-ARES”). The program searched other ARES computers for terms

associated with child pornography.3 The RU-ARES program also ran a search for

videos and pictures using a secure hash algorithm, also known as an SHA-1. Based

on the number and arrangement of pixels, every video and picture has a specific

SHA-1 value. Thus, the RU-ARES program in this case searched for the SHA-1

values of specific images and videos known to contain child pornography.

Additionally, the search was limited to IP addresses that were potentially located in

Cobb County.

On May 22, 2013, the RU-ARES program running on the police department’s

computer identified an IP address in Cobb County as having six shared files that

contained possible child pornography. Three files were downloaded to the police

department computer from that IP address on May 22, a fourth file downloaded on

May 23, and a fifth file downloaded on May 29. Sergeant Raymond Drew of the Cobb

3 These terms included “PTHC” (which stands for “preteen hard-core”); Lolita; LS Magazine (a known child pornography magazine); and any number less than 18 accompanied by the letters “YO” (the “YO” standing for “years old”).

4 County Police Department4 reviewed those files after they were downloaded and

determined that each of them contained what appeared to be child pornography.

Working with a crime analyst, Drew learned that the ISP for the IP address in

question was Comcast. Drew then prepared a grand jury subpoena for Comcast asking

them to produce the subscriber name, physical address, and other identifying

information for the IP address in question. . The subpoena was served on Comcast

and the ISP provided law enforcement with information showing that the account in

question belonged to Maddox and that the bills went to a residential address in

Marietta.

Upon learning that the computer using the IP address was associated with a

residence inside the Marietta city limits, Drew provided all of the information

regarding the investigation to Detective Mark Erion with the City of Marietta Police

Department. The information provided to Erion included Maddox’s subscriber

information and a copy of the downloaded files. After determining that Maddox lived

at the residential address in question, Erion obtained a search warrant for that

4 At the time, Sergeant Drew was a detective in the Crimes against Women and Children Unit.

5 residence. During the execution of the search warrant, police located three computers,

including a Dell desktop and a Dell laptop, both of which belonged to Maddox.

At the time the search warrant was executed, Maddox agreed to talk with police

and an audio recording of this interview was admitted and played at trial. . During

that interview, Maddox, who had majored in computer science, told police that he had

downloaded the ARES software so that he could obtain pornography from the

Internet. Maddox explained that any pornographic files he downloaded went to the

“My Shared Folder” on his desktop, and that he was the only person who had

downloaded anything to his computers. Additionally, Maddox admitted that he

located the titles of and previewed the pornographic files before downloading them,

and he admitted to downloading all of the files subsequently obtained by the State

using RU-ARES.

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James Maddox v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-maddox-v-state-gactapp-2018.