United States v. Brent Galletta

CourtCourt of Appeals for the Third Circuit
DecidedJuly 9, 2025
Docket23-2403
StatusUnpublished

This text of United States v. Brent Galletta (United States v. Brent Galletta) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Brent Galletta, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ______________

No. 23-2403

______________

UNITED STATES OF AMERICA

v.

BRENT S. GALLETTA,

Appellant ______________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 5:14-cr-00603-001) U.S. District Judge: Honorable Edward G. Smith _____________

Submitted Under Third Circuit L.A.R. 34.1(a) July 8, 2025 ______________

Before: SHWARTZ, FREEMAN, and RENDELL, Circuit Judges.

(Filed: July 9, 2025) ______________

OPINION* ______________

 This disposition is not an opinion of the full court and pursuant to I.O.P. 5.7 does not constitute binding precedent. SHWARTZ, Circuit Judge.

Brent Galletta appeals the order denying his 28 U.S.C. § 2255 motion asserting he

was denied effective assistance of counsel because his counsel did not file a suppression

motion. Because the motion would have failed, his counsel was not ineffective for not

filing it and so we will affirm.

I

A1

Galletta posted an online ad entitled “Pervy Dads—m4m—34(Mall),” seeking

fathers who are “pervy and like[] taboo stuff,” and an undercover agent posing as a father

of a young son and daughter responded. App. 293-94. Through electronic messages with

the agent, Galletta (1) expressed sexual interest in the agent’s “children” and told the

agent he was into “younger girls,” including the child of a former paramour, (2) “asked

for a picture of [the undercover agent] and [the] two children,” and (3) sent a picture of

himself. App. 294-95. After the agent and Galletta made plans to meet and Galletta

described the sexual activity he wanted to engage in with the “daughter,” App. 295, the

agent asked Galletta, “u planning on take [sic] any pics? My only rule is I don’t want

them all over the internet,” and Galletta responded, “sure and ok.” App. 295. Galletta

asked the agent to confirm that no one else would be home and “if he should bring a

laptop computer.” App. 295. When the agent asked Galletta if he wanted “[the daughter]

in anything,” Galletta said she should wear a “bikini.” App. 295.

1 We recite the facts as set forth in the affidavit submitted in support of the search warrant. 2 Galletta was arrested when he arrived for the meeting. Galletta told law

enforcement that he had previously been arrested “for the same thing,” and a criminal

history search confirmed two charges for corruption of a minor. App. 295. He also

acknowledged he used a cellular device to communicate, and an officer saw a cell phone

in Galletta’s car.

Law enforcement obtained a warrant to search Galletta’s car for “computer

hardware” including “[a]ny mobile devices such as cellular phones,” which might contain

child pornography or other evidence relating to its possession and dissemination. App.

291-92. The affidavit filed in support of the warrant described the electronic

communications Galletta had with the agent and his post-arrest statements. The search of

the phone revealed the messages between Galletta and the undercover agent, child

pornography and “child erotica” images, Suppl. App. 125, as well as surreptitiously

recorded videos of children with suggestive content.

B

Galletta was indicted for (1) enticement of a minor in violation of 18 U.S.C.

§ 2422(b); (2) transportation of child pornography in violation of 18 U.S.C. § 2252(a)(1);

and (3) possession of child pornography in violation of 18 U.S.C. § 2252(a)(4)(B).

Galletta’s trial counsel did not challenge the search warrant, despite Galleta “begg[ing]

him” to do so. Suppl. App. 455. At trial, the jury was shown, among other things, child

pornography and other images found on Galletta’s phone. A jury found him guilty of all

charges and he was sentenced to 600 months’ imprisonment with lifetime supervised

release.

3 After unsuccessfully challenging his conviction on direct appeal, United States v.

Galletta, 662 F. App’x 190, 191 (3d Cir. 2016) (not precedential), Galletta filed a § 2255

motion attacking his conviction on several grounds. Relevant here, Galletta argued that

his trial counsel was ineffective because competent counsel would have moved to

suppress the evidence found on his phone because the warrant to search for child

pornography lacked probable cause and the good faith exception did not apply. He

asserts that, had his counsel filed this motion, the fruits of this search would have been

suppressed and he would not have been convicted.

The District Court denied Galletta’s motion, concluding that any suppression

motion would have failed because the search warrant was supported by probable cause

and, even if it had not been, the good faith exception applied, and thus counsel was not

ineffective for not filing the motion. United States v. Galletta, No. 14-cr-603, 2023 WL

4565477, at *72, *75-76 (E.D. Pa. July 17, 2023).

Galletta appealed, and we issued a certificate of appealability.2

II3

To prove ineffective assistance of counsel, a defendant must show that

(1) “counsel’s performance was deficient,” and (2) the defendant suffered prejudice

2 Although Galletta filed a notice of appeal of the entire order denying him § 2255 relief, we granted a certificate of appealability on only “whether trial counsel [was] ineffective for failing to file a motion to suppress the evidence of child pornography seized from the mobile phone.” Order at 1, United States v. Galletta, No. 23-2403, (3d Cir. Feb. 28, 2024), ECF No. 11. 3 The District Court had jurisdiction pursuant to 28 U.S.C. § 2255. We have jurisdiction pursuant to 28 U.S.C. §§ 1291, 2253(a), and 2255(d). When reviewing an

4 because of the deficiency.4 Strickland v. Washington, 466 U.S. 668, 687-88, 694 (1984).

We need not address the first prong of Strickland’s conjunctive test because Galletta’s

argument fails on the second. As explained herein, he suffered no prejudice because,

even if probable cause were lacking, the suppression motion would have been denied

under the good faith exception to the exclusionary rule.

The good faith exception precludes suppressing evidence “where officers act in

‘good faith’ or ‘objectively reasonable reliance’ on a search warrant later held to be

defective.” United States v. Caesar, 2 F.4th 160, 169 (3d Cir. 2021) (quoting United

States v. Leon, 468 U.S. 897, 922 (1984)). The existence of “a warrant issued by a

magistrate normally suffices to establish that a law enforcement officer has acted in good

faith in conducting the search,” United States v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
United States v. Leon
468 U.S. 897 (Supreme Court, 1984)
People v. John
654 F.3d 412 (Third Circuit, 2011)
United States v. Williams
3 F.3d 69 (Third Circuit, 1993)
United States v. Ray Donald Loy
191 F.3d 360 (Third Circuit, 1999)
United States v. David Scott Zimmerman
277 F.3d 426 (Third Circuit, 2002)
United States v. Hodson
543 F.3d 286 (Sixth Circuit, 2008)
United States v. Brent S. Galletta
662 F. App'x 190 (Third Circuit, 2016)
United States v. Robert Caesar
2 F.4th 160 (Third Circuit, 2021)
Kay Ellison v. United States
120 F.4th 338 (Third Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Brent Galletta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-brent-galletta-ca3-2025.