United States v. Pratt

CourtCourt of Appeals for the Second Circuit
DecidedOctober 2, 2023
Docket22-1637
StatusUnpublished

This text of United States v. Pratt (United States v. Pratt) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second 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. Pratt, (2d Cir. 2023).

Opinion

22-1637-cr United States of America v. Pratt

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

1 At a stated term of the United States Court of Appeals for the Second Circuit, 2 held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the 3 City of New York, on the 2nd day of October, two thousand twenty-three. 4 5 PRESENT: REENA RAGGI, 6 RAYMOND J. LOHIER, JR., 7 SUSAN L. CARNEY, 8 Circuit Judges. 9 ------------------------------------------------------------------ 10 UNITED STATES OF AMERICA, 11 12 Appellee, 13 14 v. No. 22-1637-cr 15 16 CHRISTOPHER J. PRATT, 17 18 Defendant-Appellant. 19 ------------------------------------------------------------------ 20 1 FOR DEFENDANT-APPELLANT: RICHARD D. WILLSTATTER 2 (Theodore S. Green, on the 3 brief), Green & Willstatter, 4 White Plains, NY

5 FOR APPELLEE: PAUL David Silver, Rajit Singh 6 Dosanjh, Assistant United 7 States Attorneys, for Carla B. 8 Freedman, United States 9 Attorney for the Northern 10 District of New York, Albany, 11 NY

12 Appeal from a judgment of the United States District Court for the

13 Northern District of New York (Mae A. D’Agostino, Judge).

14 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

15 AND DECREED that the judgment of the District Court is AFFIRMED.

16 Defendant-Appellant Christopher J. Pratt appeals from a judgment of the

17 United States District Court for the Northern District of New York (D’Agostino,

18 J.) convicting him of (1) distribution of child pornography, (2) receipt of child

19 pornography, and (3) possession of child pornography involving prepubescent

20 minors or minors under the age of 12, in violation of 18 U.S.C §§ 2252A(a)(2)(A),

21 2252A(b)(1), 2252A(b)(2), 2252A(a)(5)(B), and 2256(8)(A). In July 2019 the District

22 Court denied Pratt’s pre-trial motion to suppress evidence seized during a search

23 of his home, as well as statements he made to police. In August 2021, pursuant

2 1 to a written plea agreement, Pratt entered a conditional guilty plea to all three

2 counts, reserving his right to appeal the District Court’s denial of his motion to

3 suppress evidence. Pratt was later sentenced principally to a term of 148 months’

4 imprisonment. On appeal, Pratt challenges the denial of his motion to suppress.

5 We assume the parties’ familiarity with the underlying facts and the record of

6 prior proceedings, to which we refer only as necessary to explain our decision to

7 affirm.

8 The written plea agreement permits Pratt to raise only two issues on

9 appeal: (1) “[w]hether the June 1, 2017 search warrant established probable cause

10 to believe that child pornography would be found in [his] home,” and (2)

11 “[w]hether law enforcement acted in good faith reliance on the June 1, 2017

12 search warrant when searching [his] home on June 5, 2017.” App’x 142. On

13 appeal, Pratt makes the additional argument that his statements to police should

14 be suppressed. We conclude that Pratt has waived that argument, however,

15 because it was not clearly included in the plea agreement’s reservation of issues

16 for appellate review. United States v. Coffin, 76 F.3d 494, 497 (2d Cir. 1996).

17 “On appeal from a district court’s ruling on a motion to suppress, we

18 review the court’s factual findings for clear error. We review the court’s legal

3 1 determinations, including the existence of probable cause and the good faith of

2 officers relying on a search warrant, de novo.” United States v. Raymonda, 780

3 F.3d 105, 113 (2d Cir. 2015).

4 Pratt argues that there was no probable cause supporting the warrant in

5 this case because “no verbal description of the [computer] files was provided” to

6 the judge who authorized the warrant. Appellant’s Br. 17(quotation marks

7 omitted). Pratt also argues that the information contained in the search warrant

8 was “too stale to be relied upon” because the “warrant application described just

9 a single download of files . . . eight months prior to the application.” Appellant’s

10 Br. at 21-22; see Raymonda, 780 F.3d at 114 (“[W]e may conclude that a warrant

11 lacks probable cause where the evidence supporting it is not sufficiently close in

12 time to the issuance of the warrant that probable cause can be said to exist as of

13 the time of the search — that is, where the facts supporting criminal activity have

14 grown stale by the time that the warrant issues.”) (quotation marks omitted).

15 We need not resolve the probable cause issue because we agree with the

16 District Court that the good faith exception to the exclusionary rule applies even

17 assuming that probable cause was lacking. See United States v. Jones, 43 F.4th 94,

18 110–11 (2d Cir. 2022); United States v. Boles, 914 F.3d 95, 103 (2d Cir. 2019). Pratt

4 1 relies on our decision in Raymonda to argue that the good faith exception does not

2 apply for two reasons.

3 First, Pratt describes the warrant as “so lacking in indicia of probable cause

4 as to render official belief in its existence entirely unreasonable.” Appellant’s Br.

5 7. The issue of whether a warrant contains adequate indicia of probable cause

6 “most frequently arises when affidavits are bare bones—that is, when they are

7 totally devoid of factual circumstances to support conclusory allegations.” Jones,

8 43 F.4th at 112 (quotation marks omitted). “The concern is particularly acute

9 when facts indicate that the bare-bones description . . . was almost calculated to

10 mislead.” United States v. Clark, 638 F.3d 89, 103 (2d Cir. 2011) (quotation marks

11 omitted). “We have emphasized that this is a very difficult threshold to meet.”

12 Jones, 43 F.4th at 112 (quotation marks omitted, emphasis supplied).

13 We do not agree that the warrant application in this case was “totally

14 devoid” of factual support such that it was unreasonable to rely on it. Clark, 638

15 F.3d at 103. To be sure, the warrant application approaches the line between just

16 enough and too little specificity with respect to the description of the computer

17 files at issue. But the warrant application did advise that another FBI Task Force

5 1 Officer downloaded files that “consisted of” child pornography from a

2 BitTorrent “share” folder that was later connected to Pratt. App’x 34.

3 We have explained that “[w]here a relevant legal deficiency was not

4 previously established in precedent, [an] agent’s failure to recognize that

5 deficiency cannot vitiate good faith.” Raymonda, 780 F.3d at 119 (quotation

6 marks omitted).

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Related

United States v. Clark
638 F.3d 89 (Second Circuit, 2011)
United States v. John Coffin
76 F.3d 494 (Second Circuit, 1996)
Sternberger v. McGovern
11 N.Y. 12 (New York Court of Appeals, 1874)
United States v. Jones
43 F.4th 94 (Second Circuit, 2022)
United States v. Boles
914 F.3d 95 (Second Circuit, 2019)

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United States v. Pratt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-pratt-ca2-2023.