United States v. James A. Bethel

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 19, 2024
Docket23-3668
StatusUnpublished

This text of United States v. James A. Bethel (United States v. James A. Bethel) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. James A. Bethel, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0174n.06

Case Nos. 23-3482/3668

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Apr 19, 2024 ) UNITED STATES OF AMERICA, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE SOUTHERN DISTRICT OF JAMES A. BETHEL, ) OHIO Defendant-Appellant. ) ) OPINION

Before: COLE, CLAY, and THAPAR, Circuit Judges.

THAPAR, Circuit Judge. While executing a warrant to search all electronic devices at a

residence, officers found child pornography on James Bethel’s cell phone. Bethel argues the

warrant didn’t support the search of his phone. We disagree. But the district court imposed

restitution without calculating the victim’s losses, so we affirm in part, vacate in part, and remand

for further proceedings.

I.

As part of a child pornography investigation, a law enforcement officer observed a social

media user named “boninick63” share images and videos of child sexual abuse online. Officers

determined the account belonged to “Nick Bonavita” and focused their efforts on him. Bonavita’s

account logged in from two IP addresses. One IP address came from a cell phone tied to Bonavita.

The other IP address was registered to a “Barb Bethel” at a mobile home on Sioux Court in Nos. 23-3482/3668, United States v. Bethel

southern Ohio. Police knew from employment records that Bonavita resided at that mobile home.

Although it’s unclear whether officers knew this at the time, Bonavita’s uncle, James Bethel, also

lived there.

Based on this information, officers obtained a warrant to search the mobile home. The

warrant authorized the search and seizure of any computers and cell phones located on the premises

that could be used to display child pornography.

Bethel was present when officers executed the search warrant. After agreeing to a

voluntary interview, Bethel asked officers to retrieve his unlocked cell phone from his bedroom.

Officers then searched Bethel’s phone and found child pornography. Upon obtaining another

warrant, officers searched Bethel’s online storage accounts and discovered more child

pornography, as well as evidence that someone attempted to delete files after the initial search.

The United States charged both Bonavita and Bethel with child pornography offenses.

Bonavita pled guilty. Bethel moved to suppress the evidence found on his phone, arguing that the

warrant’s scope exceeded the probable cause supporting it. The district court denied the motion,

explaining there was probable cause to search all phones at the mobile home. The court held a

bench trial and found Bethel guilty of possessing child pornography, receiving and distributing

child pornography, and destroying records in a federal investigation. The district court sentenced

Bethel to 60 months’ imprisonment. Over Bethel’s objection, the court also imposed $3,000 in

restitution. The government didn’t introduce evidence quantifying the harm Bethel caused his

victims. But the court, acknowledging that “the specific magnitude of the loss [was] not well-

documented,” nonetheless concluded that $3,000 was the default mandatory amount because the

victim’s loss was “obviously greater than a penny.” See 18 U.S.C. § 2559(b)(2)(B). Bethel now

appeals, challenging (1) the denial of his suppression motion and (2) the restitution order.

-2- Nos. 23-3482/3668, United States v. Bethel

II.

A.

Bethel appears to make two arguments challenging the warrant. First, he suggests the

warrant’s terms only covered Bonavita’s devices—not his. Second, even if the warrant did include

his phone, Bethel argues probable cause didn’t support that inclusion.

The first argument is unavailing. The warrant authorized the search of “any and all

computer software” and “[c]omputer(s), including cell phones” found at the Sioux Court address

that may be used to access child pornography. R. 21-1, Pg. ID 81. Bethel’s phone falls within that

description: police found it at the Sioux Court address, and it could’ve been used to access child

pornography. Thus, the warrant covered his phone.

Bethel next argues officers didn’t have probable cause to search his phone. The Fourth

Amendment requires search warrants to be supported by probable cause. U.S. Const. amend. IV.

And probable cause exists if there’s a “fair probability” that evidence of a crime will be found at

the location to be searched. United States v. Berry, 565 F.3d 332, 338 (6th Cir. 2009) (citation

omitted).

Here, police had probable cause to believe evidence of child pornography would be found

on any phone in the mobile home, including Bethel’s. The IP address used to share child

pornography was tied to the Sioux Court mobile home where Bonavita and Bethel lived. Our

circuit has repeatedly held in child pornography cases that this fact alone shows that probable cause

existed to issue a valid search warrant for the search of electronic devices found in the residence.

See United States v. Hinojosa, 606 F.3d 875, 885 (6th Cir. 2010); cf. United States v. Gillman, 432

F. App’x 513, 515 (6th Cir. 2011); United States v. Wagers, 452 F.3d 534, 539 (6th Cir. 2006);

United States v. Richards, 659 F.3d 527, 538–40 (6th Cir. 2011). But the warrant affidavit went

-3- Nos. 23-3482/3668, United States v. Bethel

further. It noted that digital files can easily be shared across devices. An officer testified that child

pornographers often use aliases—supporting the conclusion that Bonavita might not be the only

responsible party. And the warrant confirmed any device connected to the premises’s wireless

network would use the same IP address associated with the illegal activity. In sum, this evidence

is more than enough to authorize searching Bethel’s phone.

To be sure, the affidavit focused specifically on Bonavita and didn’t mention Bethel.

Bethel argues that shows officers only had probable cause to search Bonavita’s devices. But that’s

not the case. To see why, compare two different warrant applications. One contains information

tying child pornography to the Sioux Court IP address and doesn’t mention any identifying

information, phone numbers, or account usernames. Under our precedent, that would establish

probable cause to search all electronic devices at the residence. Hinojosa, 606 F.3d at 885;

Richards, 659 F.3d at 538–40. Now imagine another warrant application. This time, in addition

to connecting child pornography to the IP address, it provides information linking the pornography

to a specific resident. According to Bethel, that stronger evidence should lead to a weaker search

warrant. We decline to create a perverse incentive by telling officers the more information they

provide, the weaker the probable cause.

In sum, the magistrate judge did not “arbitrarily” find probable cause to search any cell

phones found at the residence. United States v. Allen, 211 F.3d 970, 973 (6th Cir. 2000) (en banc).

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