USA v David Morel

2017 DNH 072
CourtDistrict Court, D. New Hampshire
DecidedApril 14, 2017
Docket14-CR-148-01-JL
StatusPublished
Cited by1 cases

This text of 2017 DNH 072 (USA v David Morel) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v David Morel, 2017 DNH 072 (D.N.H. 2017).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Civil No. 14-cr-148-JL Opinion No. 2017 DNH 072 David Morel

OPINION AND ORDER

In advance of a trial on one count of possession of child

pornography, see 18 U.S.C. § 2252(a)(4)(B), defendant David

Morel Jr. filed a series of motions to suppress evidence. These

motions turn on whether he had a reasonable expectation of

privacy in images uploaded to the Internet and whether probable

cause supported a warrant to search a computer for child

pornography when the affiant police detective failed to attach

known images of apparent child pornography to the warrant

application.

By his first motion, Morel asked the court to suppress

images of child pornography obtained from his computer and

statements he made during a custodial interrogation, arguing

that this evidence was obtained as the result of a warrantless

search conducted by Imgur, a corporation, acting at the

instigation of the National Center for Missing and Exploited Children (NCMEC).1 By his second motion, Morel sought to

suppress the images obtained from his computer because, he

argues, it was searched pursuant to a constitutionally-deficient

warrant.2 Morel also filed a third motion, seeking to suppress

evidence obtained from what he contended was an unconstitutional

warrantless arrest.3

After two evidentiary hearings, one on Morel’s first motion

to suppress and the other on Morel’s second and third motions,

the court denied all three motions.4 Morel subsequently

conditionally pleaded guilty to one count of possessing child

pornography in violation of 18 U.S.C. § 2252(a)(4)(B), reserving

the right to appeal the court’s orders denying his first and

second motions.5 See Fed. R. Crim. P. 11(a)(2). This order

serves to set forth the bases for the court’s denial of those

two motions in greater detail. See, e.g., United States v.

1 Morel filed a series of motions and supplemental motions in support of his arguments to this effect. See document nos. 24, 31, 33, 35, 40. The court considers this set of documents to constitute a single motion. 2 Document no. 51. 3 Document no. 49. 4 See Orders of April 4, 2016, September 22, 2016, and September 30, 2016. 5 Because Morel thus waived his right to appeal the court’s denial of his third motion to suppress, the court does not elaborate on its reasoning in this order.

2 Joubert, 980 F. Supp. 2d 53, 55 n.1 (D.N.H. 2014), aff'd, 778

F.3d 247 (1st Cir. 2015) (citing In re Mosley, 494 F.3d 1320,

1328 (11th Cir. 2007) (noting a district court’s authority to

later reduce its prior oral findings and rulings to writing).

As explained below, Morel vigorously argues that Imgur

reviewed his uploaded images at the behest of NECMEC and, thus,

that Imgur’s review amounted to a warrantless governmental

search. Because Morel fails to establish that he possessed a

reasonable expectation of privacy in the uploaded images, the

court need not reach that question. The images, uploaded to the

Internet, were not only accessible to but actually accessed by

an anonymous tipster and NCMEC, strongly suggesting that Morel

lacked any such expectation. As to his second motion, though

the affiant failed to follow the “best practice” of attaching

the known images of alleged child pornography to his affidavit

in support of a warrant, his affidavit did not run afoul of the

requirement that a judicial officer, not the investigating

officer, make the probable cause determination because he

sufficiently described the manner in which the images met the

statutory requirements for child pornography. Accordingly, the

court denied both motions.

3 Background

The court makes the following findings of fact based on the

testimony and other evidence received at the suppression

hearings.

A. NCMEC CyberTipline report

The National Center for Missing and Exploited Children

(NCMEC) is a non-profit organization that works to reunite

missing children with their families, reduce child sexual

exploitation, and prevent child victimization. See 42 U.S.C.

§ 5771. To further that mission, NCMEC hosts a CyberTipline --

a website through which members of the public, law enforcement

officials, and others can report child exploitation and child

pornography by filling out a form on that website. Id.

§ 5773(b)(1). The law obligates electronic service providers

(ESPs) that “obtain[] actual knowledge of” child pornography to

report that fact to NCMEC through the CyberTipline. 18 U.S.C.

§ 2258A(a). Knowing and willful failure to do so is may be

punished by a fine. Id. § 2258A(e). Upon receiving such a

report, NCMEC must forward it to an appropriate federal law

enforcement agency, and may forward it to an appropriate state

or foreign law enforcement agency. Id. § 2258A(c).

The CyberTipline’s online form contains several fields.

While an individual or ESP reporting an instance of child

pornography may fill out many or all of the fields available,

4 including contact information, only two fields are required:

the date and time of the incident, and the substance of the

report. An individual making a report can provide the web

address of any files containing child pornography; he or she

cannot, however, upload the image files. ESPs, on the other

hand, can upload and attach images to those reports.

Irrespective of how many or which fields someone making a report

fills out, NCMEC automatically captures the date and time that a

report is submitted, as well as the IP address of the computer

from which it was submitted.

On November 23, 2013, an unidentified individual reported

instances of child pornography through the CyberTipline (report

number 2195842), including a list of URLs of websites or images

appearing to depict child pornography.6 This person provided no

identifying information, but the CyberTipline captured his or

her IP address and, via an automated process, populated the

location associated with that IP address into the report.

NCMEC’s staff analysts then visited several of the reported URLs

and annotated the report, indicating whether the visited URLs

appeared to contain child pornography. In this report, one of

the URLs led to a gallery of images hosted by an image-hosting

6 Hearing Ex. 2.

5 service called Imgur.7 The analyst obtained the URLs of specific

images in the gallery that appeared to contain child pornography

without clicking on the links thereto, and copied those URLs

into the report.8

Once a day, NCMEC sends automated notices to ESPs

summarizing instances of apparent child pornography reported

from or found on their websites that day. On November 26, 2013,

NCMEC sent such a notice to Imgur, indicating that images found

at Imgur URLs appeared to contain child pornography, including

images identified in report number 2195842.9 In this notice,

NCMEC asked Imgur to “[p]lease review the reported URL to

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