United States v. Gitarts

341 F. App'x 935
CourtCourt of Appeals for the Fourth Circuit
DecidedAugust 28, 2009
Docket08-5003
StatusUnpublished

This text of 341 F. App'x 935 (United States v. Gitarts) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth 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. Gitarts, 341 F. App'x 935 (4th Cir. 2009).

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 08-5003

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

BARRY E. GITARTS,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Liam O’Grady, District Judge. (1:07-cr-00464-LO-1)

Submitted: July 29, 2009 Decided: August 28, 2009

Before WILKINSON, MICHAEL, and SHEDD, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Jonathan L. Katz, JON KATZ, P.C., Silver Spring, Maryland, for Appellant. Dana J. Boente, United States Attorney, Jay V. Prabhu, Assistant United States Attorney, Josh Goldfoot, Tyler G. Newby, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit. PER CURIAM:

Barry E. Gitarts was convicted of conspiracy to

defraud the United States, in violation of 18 U.S.C. § 371

(2006). He received a sentence of eighteen months’

imprisonment. Gitarts raises several issues on appeal:

(1) evidence obtained from searches of his home and remote

computer server should have been suppressed; (2) the indictment

should have been dismissed for failing to sufficiently charge a

crime; (3) statements made by Gitarts during questioning at his

residence should have been suppressed; (4) venue did not

properly lay in the Eastern District of Virginia; (5) the

district court improperly admitted business records in violation

of the Confrontation Clause; (6) the evidence against him was

insufficient to support the conviction; (7) the district court

abused its discretion in providing the indictment to the jury

during its deliberations; and (8) his sentence was unreasonable.

We affirm.

I. Searches of Gitarts’s Home and the TSV Server

Gitarts asserts that the searches executed on his home

and on the TSV server, a computer server located in Texas,

should have been suppressed because the authorities lacked

probable cause. In reviewing the district court’s ruling on a

motion to suppress, we review the district court’s factual

2 findings for clear error and its legal determinations de novo.

United States v. Cain, 524 F.3d 477, 481 (4th Cir. 2008). The

facts are reviewed in the light most favorable to the prevailing

party below. United States v. Jamison, 509 F.3d 623, 628 (4th

Cir. 2007).

The relevant inquiry when reviewing the propriety of

the issuance of a search warrant is whether, under the totality

of the circumstances, the issuing judge had a substantial basis

for concluding there was probable cause to issue the warrant.

See Illinois v. Gates, 462 U.S. 213, 238-39 (1983). The facts

presented to the issuing judge need only convince a person of

reasonable caution that contraband or evidence of a crime will

be found at the place to be searched. Texas v. Brown, 460 U.S.

730, 742 (1983). Reviewing courts afford great deference to a

magistrate’s finding of probable cause. See Gates, 462 U.S. at

236.

It is clear that the TSV warrant was supported by

probable cause. The affidavits presented in support of the

warrant explicitly detailed the information given to the FBI by

the Recording Industry Association of America (“RIAA”)

concerning an underground music piracy conspiracy known as

Apocalypse Production Crew (“aPC”) and its distribution of

pirated material. A confidential informant worked with the

RIAA, allowing the RIAA to access infringing music files stored

3 on the TSV server and download them directly to an independent

contractor working with the RIAA. On this basis, the RIAA

provided the government with (1) infringing music titles

downloaded by the independent contractor from TSV; (2) transfer

logs showing such downloads; (3) sample screen shots of the

downloads; (4) a listing of several TSV directories; (5) logs of

chat groups between aPC members. This information was

independently analyzed and confirmed by the FBI. The FBI then

learned the location of the server by way of its IP address, and

through the server’s internet service provider (“ISP”). In

light of the great deference due to the judgment of the issuing

magistrate, Gates, 462 U.S. at 236, we find that probable cause

supported the issuance of the warrant for the TSV server.

We reach the same result regarding the affidavit

supporting the warrant for a search of Gitarts’s residence. In

addition to incorporating the information in support of the TSV

warrant, the affidavit contained further information linking

Gitarts to aPC and the TSV server. Records turned over by the

ISP indicated that Gitarts was paying for the TSV’s ISP services

from his New York residence. Records from PayPal, an online

money transfer service, indicated a monetary transfer from Paul

Davis, the leader of aPC, to Gitarts. Moreover, analysis of

data contained on the TSV server indicated that someone had

accessed the server as an administrator on more than one

4 occasion from a computer located at Gitarts’s residence.

Therefore, we find that probable cause supported issuance of the

warrant for a search of Gitarts’s residence.

II. Statements Made by Gitarts

Gitarts next contends the district court erroneously

determined Gitarts was not in custody at the time he gave

statements to authorities during the search of his apartment.

Therefore, according to Gitarts, the district court erred in

denying the motion to suppress his statements.

Statements obtained from an individual during a

custodial interrogation are presumptively compelled in violation

of the Fifth Amendment, unless the Government shows that law

enforcement officers adequately informed the individual of his

Miranda 1 rights and secured a waiver of those rights. United

States v. Cardwell, 433 F.3d 378, 388 (4th Cir. 2005). An

individual is in custody for Miranda purposes when, under the

totality of the circumstances, the individual’s “freedom of

action is curtailed to a degree associated with formal arrest.”

Berkemer v. McCarty, 468 U.S. 420, 440 (1984) (internal

quotation marks and citation omitted). Thus, an individual may

still be “in custody” even when informed that he is not under

1 Miranda v. Arizona, 384 U.S. 436 (1966).

5 arrest, if a “reasonable man in [his] position would have

understood his situation to be one of custody.” United

States v. Colonna, 511 F.3d 431, 435 (4th Cir. 2007) (internal

quotation marks and citation omitted).

Here, Gitarts was not in custody during his

questioning. Gitarts was questioned in his own home in the

presence of his family. He was not handcuffed or otherwise

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Related

Glasser v. United States
315 U.S. 60 (Supreme Court, 1942)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Texas v. Brown
460 U.S. 730 (Supreme Court, 1983)
Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
Berkemer v. McCarty
468 U.S. 420 (Supreme Court, 1984)
United States v. Cabrales
524 U.S. 1 (Supreme Court, 1998)
Crawford v. Washington
541 U.S. 36 (Supreme Court, 2004)
Melendez-Diaz v. Massachusetts
557 U.S. 305 (Supreme Court, 2009)
United States v. Kymberli Parker
262 F.3d 415 (Fourth Circuit, 2001)
United States v. Robert B. Miller
316 F.3d 495 (Fourth Circuit, 2003)
United States v. Amy Tucker
376 F.3d 236 (Fourth Circuit, 2004)
United States v. Christopher Robinson
389 F.3d 582 (Sixth Circuit, 2004)
United States v. Russell Lee Ebersole
411 F.3d 517 (Fourth Circuit, 2005)
United States v. Warren Collins
412 F.3d 515 (Fourth Circuit, 2005)
United States v. Foster
507 F.3d 233 (Fourth Circuit, 2007)
United States v. Jamison
509 F.3d 623 (Fourth Circuit, 2007)
United States v. Johnson
510 F.3d 521 (Fourth Circuit, 2007)
United States v. Colonna
511 F.3d 431 (Fourth Circuit, 2007)

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