State of Louisiana v. Timothy Eric Daigle

CourtLouisiana Court of Appeal
DecidedMay 2, 2012
DocketKA-0011-1209
StatusUnknown

This text of State of Louisiana v. Timothy Eric Daigle (State of Louisiana v. Timothy Eric Daigle) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana v. Timothy Eric Daigle, (La. Ct. App. 2012).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

KA 11-1209

STATE OF LOUISIANA

VERSUS

TIMOTHY ERIC DAIGLE

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 295,729 HONORABLE THOMAS MARTIN YEAGER, DISTRICT JUDGE

BILLY HOWARD EZELL JUDGE

Court composed of John D. Saunders, Marc T. Amy, and Billy Howard Ezell, Judges.

AFFIRMED.

James C. Downs District Attorney 701 Murray Street Alexandria, LA 71301 (318) 473-6650 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana

George Lewis Higgins, III P. O. Box 3370 Pineville, LA 71361-3370 (318) 473-4250 COUNSEL FOR DEFENDANT/APPELLANT: Timothy Eric Daigle Monique Yvette Metoyer 2729 Overton St. Alexandria, LA 71301 (318) 473-6650 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana EZELL, Judge.

On June 13, 2011, Defendant, Timothy Eric Daigle, pled guilty to one count

of pornography with juveniles, in violation of La.R.S. 14:81.1. As part of his plea

bargain, Defendant received a two-year hard labor sentence without benefit of

probation, parole, or suspension of sentence; Defendant was credited for time

served; Defendant was required to register as a sex offender, and Defendant

reserved the right to contest the trial court‟s ruling on his motions to suppress

evidence under State v. Crosby, 338 So.2d 584 (La.1976).

The record shows that, prior to his guilty plea, Defendant filed a “Motion to

Suppress Warrant and Incorporated Memorandum” on September 25, 2009. In his

motion, Defendant contended that, contrary to law enforcement‟s assertion that the

files were in “plain sight,” the files were illegally seized from Defendant‟s home

computer as Defendant‟s home computer neither broadcasted nor transmitted any

information concerning the content of Defendant‟s hard drive. Further, the

prosecution did not allege that any such transmission or broadcast occurred.

Defendant additionally urged that the only way the files could be viewed was

through the use of complex decryption software. Defendant continued that the title

“secure hash algorithm values,” SHA values, implied an expectation of privacy in

addition to the encryption placed on the files. The presence of a firewall on

Defendant‟s computer also added to his expectation of privacy.

On November 30, 2009, the trial court denied Defendant‟s motion to

suppress:

Mr. Daigle is present. United States versus Stults, S-T-U-L-T-S, it is cited as 575 Federal 3rd, 834, and it was filed August 14, 2009, It‟s United States District Court the 8th Circuit Court of Appeal in Nebraska.

.... And, the case says, basically, that there is no expectation of privacy on your client‟s part in this case. He filed sharing information that was seized by the police. There was no expectation of privacy.

Basically, it says, “as a result, although it was a jail matter, an individual has an objectively reasonable expectation of privacy in his personal computer, we fail to see how this expectation can survive the defendant‟s decision to install and use file sharing software, thereby opening his computer to anyone else with the same freely available program.” So it discusses the same issues that we have in our case with Daigle. It is completely on point with the Daigle issue. And, based upon this decision and all the cases that it cites, I‟m going to deny your Motion to Suppress the evidence that was seized from Mr. Daigle, that we previously have heard testimony on.

On April 12, 2010, the defense filed a “Supplemental Motion to Suppress

and Incorporated Memorandum” with the trial court. In this supplemental motion,

Defendant pointed out that Detective Chad Gremillion with the Louisiana State

Police testified that he did not download any files but viewed the SHA-1 values for

the file, which were available to the general public. Defendant claimed that

Detective Gremillion viewed the SHA-1 values by using the Wyoming Tool Kit,

which has access to a database of SHA-1 values that may be associated with child

pornography.

Defendant claimed that the State failed to establish probable cause because it

relied solely on the information in that database, which was prohibited by the

“Internet Crimes Against Children Data Network Access and Use Agreement,”

IDN, for the Wyoming Tool Kit. Further, the program did not vouch for the

completeness or accuracy of the information contained in the “IDN.” Despite this

statement that the program could not guarantee the accuracy of the information,

Detective Gremillion relied solely upon the database to establish probable cause.

He did not actually view the files or consult with the source agency before taking

action. Defendant urges, therefore, that “the warrant was not based upon proper

probable cause.”

2 On June 28, 2010, Defendant filed a “Second Supplemental Motion to

Suppress” in open court. In this motion, the defense alleged that the ICAC,

Internet Crimes Against Children, database only produced files possibly consistent

with child pornography and that the database was not available to the public.

Thus, the information contained in the affidavit supporting the warrant application

was not true as the Wyoming Tool Kit and ICAC database are only available to

members of law enforcement. Defendant argued that the trial court should not

apply cases involving BearShare to the instant case because neither that program

nor any other third-party peer sharing software was used in investigating

Defendant. Defendant asserted he had an expectation of privacy because he had a

binding contract with BearShare that limited file sharing access to other members.

On October 11, 2010, the district court denied Defendant‟s second

supplemental motion to suppress. Then, on June 13, 2011, the district court

clarified that it had denied relief on all of Defendant‟s motions to suppress.

Defendant now appeals.

STATEMENT OF FACTS

The parties appeared for a pretrial discovery hearing on September 28, 2009.

Defense counsel requested and received permission to proceed with the motion to

suppress hearing as far as possible. Detective Chad Gremillion with the Louisiana

State Police was called as the State‟s sole witness. Detective Gremillion was

involved in investigating Defendant on October 2, 2008, when he began a peer to

peer proactive investigation. During the investigation, Detective Gremillion

identified an internet protocol, “IP,” address, which was basically a telephone

number, for a specific place where internet service was provided. Through

information provided by the Wyoming Tool Kit, Detective Gremillion saw that the

3 IP address “had been seen” with SHA values that were consistent with child

Detective Gremillion explained that the Wyoming Tool Kit was a program

designed by the Wyoming Department of Justice that ran on the Gnutella network.

Software such as Limewire and BearShare also ran on the Gnutella network. The

Wyoming Tool Kit identified IP addresses that had SHA values matching images

previously identified as child pornography. Detective Gremillion described a SHA

value as “a unique DNA fingerprint of a particular image.” Every computer file

was assigned either a SHA value or a MD5 value. The SHA value was an

alphanumeric string of approximately sixteen characters. Different copies of the

same file could not have different SHA values.

Detective Gremillion stated that, based on the information obtained from the

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Related

United States v. Perrine
518 F.3d 1196 (Tenth Circuit, 2008)
State v. Crosby
338 So. 2d 584 (Supreme Court of Louisiana, 1976)
United States v. Stults
575 F.3d 834 (Eighth Circuit, 2009)
United States v. Borowy
595 F.3d 1045 (Ninth Circuit, 2010)
United States v. Ganoe
538 F.3d 1117 (Ninth Circuit, 2008)
State v. Bargeman
721 So. 2d 964 (Louisiana Court of Appeal, 1998)

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