Microsoft reports child porn in OneDrive accounts

Microsoft found child pornography in a folder saved by defendant on its cloud service, and it reported it to NCMEC. Law enforcement was afraid to contact him directly because he might delete images, so they found he was on probation and went to his PO. The PO went with the officers and conducted a search of defendant’s person and belongings other than his computer. A warrant was used on the computer. The searches were valid. Defendant’s motion to suppress was not timely, and the excuse that he was in jail away from his lawyer doesn’t cut it, particularly after the motion deadline was extended. United States v. Martin, 2016 U.S. Dist. LEXIS 51619 (E.D.N.C. Feb. 3, 2016),* adopted 2016 U.S. Dist. LEXIS 51620 (E.D.N.C. Apr. 18, 2016).*

Defendant waived appellate review of the sufficiency of the location description in the search warrant for his property because the issue was not raised in the lower court. The police had sufficient probable cause and exigent circumstances to warrant the temporary seizure of the premises while they obtained a search warrant because, from adjoining land, they saw defendant tending to the area next to a growing marijuana plant. State v. Powell, 2016 Tenn. Crim. App. LEXIS 294 (April 19, 2016).*