United States v. Robert Thurman Adams

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 21, 2024
Docket24-5066
StatusUnpublished

This text of United States v. Robert Thurman Adams (United States v. Robert Thurman Adams) 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. Robert Thurman Adams, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0412n.06

No. 24-5066

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Oct 21, 2024 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY ROBERT THURMAN ADAMS, ) Defendant-Appellant. ) OPINION ) )

Before: COLE, MATHIS, and BLOOMEKATZ, Circuit Judges.

BLOOMEKATZ, Circuit Judge. State police uncovered thousands of child pornography

files while executing a search warrant at Robert Adams’s apartment. Adams argues that the search

warrant was invalid because it was based on stale information and because it relied on the results

of a fellow officer’s investigation without independent verification. The district court rejected

these arguments and denied Adams’s motion to suppress the evidence from the search. We affirm.

Factual Background

Sergeant Adam Daniels of the Ashland Police Department saw a Kentucky IP address

appear on a police database tracking online child sexual abuse material (“CSAM”). On December

8, 2020, Sergeant Daniels learned that the IP address belonged to Robert Adams. Three months

later, the same database indicated more CSAM activity by Adams. Overall, it connected Adams’s

IP address to at least 444 “files of interest,” 238 of which were “severe files.” Plea Agreement, R.

23, PageID 86; Warrant and Aff., R. 18-1, PageID 67. Ashland police officers surveilled Adams’s No. 24-5066, United States v. Adams

residence and spoke with his apartment manager. They learned that Adams was the sole tenant at

his apartment and there were no open WiFi networks in the area.

Sergeant Daniels shared this information with Detective David Boarman of the Kentucky

State Police. Relying on Sergeant Daniels’s investigations, Detective Boarman applied for and

received a search warrant for Adams’s apartment. He executed the warrant two days later, on April

9, 2020. A forensic examination of the devices gathered during the search revealed thousands of

CSAM images. Adams has since admitted to knowingly possessing “more than 600 visual

depictions” of minor children, including toddlers, “engaged in sexually explicit conduct.” Plea

Agreement, R. 23, PageID 87.

A federal grand jury indicted Adams for knowing possession of child pornography. See 18

U.S.C. § 2252(a)(4)(B). He moved to suppress the evidence that was gathered from his apartment.

Following the court’s denial of that motion, Adams entered into a conditional plea agreement,

reserving his right to appeal the denial of his motion to suppress. The district court sentenced

Adams to 97 months’ imprisonment and 10 years of supervised release. He now appeals the district

court’s suppression decision.

ANALYSIS

On appeal from the denial of a motion to suppress, we review the district court’s factual

findings for clear error and legal conclusions de novo. United States v. Trice, 966 F.3d 506, 512

(6th Cir. 2020). Adams challenges the district court’s denial of his suppression motion on two

grounds. First, he argues that the information provided in Detective Boarman’s search warrant

affidavit was stale. Second, he asserts that Detective Boarman had to independently corroborate

Sergeant Daniels’s investigations before seeking the warrant. Both arguments are unavailing.

-2- No. 24-5066, United States v. Adams

I. Staleness Approximately four months transpired between the date that Sergeant Daniels first

discovered Adams’s criminal activity (December 8, 2020), and the execution of the search warrant

(April 9, 2021). Adams argues that this four-month lapse meant that the information Detective

Boarman provided in the warrant affidavit was stale, invalidating the resulting search warrant.

Stale information cannot support probable cause for a search warrant. United States v.

Frechette, 583 F.3d 374, 377 (6th Cir. 2009). We consider information stale when, because of the

passage of time, it no longer suggests a fair probability that evidence of crime will be found at the

search location. United States v. Abboud, 438 F.3d 554, 572 (6th Cir. 2006). There is no

mechanical calculation for determining whether information is stale. Rather, staleness depends on

the “circumstances of each case” and the “nature of the crime” at issue. United States v. Paull, 551

F.3d 516, 522 (6th Cir. 2009) (quoting United States v. Hython, 443 F.3d 480, 485 (6th Cir. 2006)).

To help us evaluate whether information in a warrant affidavit is stale, we consider four factors:

(1) the character of the crime; (2) the extent of the defendant’s movement from place to place;

(3) the life span of the evidence to be seized; and (4) the location to be searched. Frechette, 583

F.3d at 378. Adams concedes the first and third factors and does not address the other two.

Considering all four factors, the challenged four-month-old information was not stale.

Character of the crime. The risk that information will go stale is higher for isolated or

short-lived crimes, and lower for recurring or continuous ones. Id. Consider a one-time theft

offense. If the police wait months before conducting a search, it is less likely that the stolen goods

will still be at the same location. Compare that with an ongoing drug trafficking scheme. Because

that crime is continuous, the police are more likely to find incriminating evidence at a given

location even if some months have passed. We have explained that possession of child

-3- No. 24-5066, United States v. Adams

pornography “is generally carried out” continuously “over a long period,” so the “time limitations

that have been applied to more fleeting crimes do not control the staleness inquiry for child

pornography.” Paull, 551 F.3d at 522. Here, police investigations revealed that Adams’s conduct

occurred not on one discrete occasion, but multiple times from at least December 2020 to March

2021. Given Adams’s recurring criminal activity, this factor weighs against staleness. Abboud, 438

F.3d at 573.

Defendant’s movement from place to place. If a defendant moves “from place to place,”

there is a lower “probability of finding evidence at a given location.” Id. Adams, however, was not

transient. All the criminal activity in this case occurred at one address—Adams’s home. This too

weighs against staleness.

Life span of evidence. The “life span” of the evidence sought in the search warrant—CSAM

computer files—also undermines Adams’s claim of staleness. Frechette, 583 F.3d at 379. Adams

concedes that “evidence of child pornography can last for long periods of time.” Reply Br. at 9.

Unlike narcotics, CSAMs are not gone after the first use. Digital CSAM in particular “can be easily

duplicated and kept indefinitely,” Frechette, 583 F.3d at 379, and can be recovered from a device

by law enforcement forensics even after it has been deleted, United States v. Elbe, 774 F.3d 885,

891 (6th Cir. 2014). Given the nature of the evidence at issue, this factor also comes out against

staleness.

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

Related

United States v. Lewis
605 F.3d 395 (Sixth Circuit, 2010)
United States v. Andre Hython
443 F.3d 480 (Sixth Circuit, 2006)
United States v. Ruben Ranke
480 F. App'x 798 (Sixth Circuit, 2012)
United States v. Charles Kinison, Jr.
710 F.3d 678 (Sixth Circuit, 2013)
United States v. Lapsins
570 F.3d 758 (Sixth Circuit, 2009)
United States v. Terry
522 F.3d 645 (Sixth Circuit, 2008)
United States v. Frechette
583 F.3d 374 (Sixth Circuit, 2009)
United States v. Paull
551 F.3d 516 (Sixth Circuit, 2009)
United States v. Kenneth Elbe
774 F.3d 885 (Sixth Circuit, 2014)
Julie Peffer v. Mike Stephens
880 F.3d 256 (Sixth Circuit, 2018)
United States v. Raheim Trice
966 F.3d 506 (Sixth Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Robert Thurman Adams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-robert-thurman-adams-ca6-2024.