N.D.Fla.: FBI had PC there was CP on electronic storage media hidden in plastic bags in a woodpile

“[A]pplying the totality of the circumstances test the Court has little difficulty concluding there was sufficient probable cause to search the electronic storage media provided to the F.B.I. For starters, a simple examination of the items to be searched evidences that there is fair probability the items contain child pornography. … Notably, these items were turned over in plastic bags, which had been stored under a woodpile. Common sense dictates that there is no legitimate reason or explanation for storing electronic storage devices outside in plastic bags under a woodpile. There is no reason for any individual to do this and certainly no reason for an individual who lives in rural Dixie County to bury digital storage devices underground. Had the CS simply presented the digital storage devices to the F.B.I. and told them he found the items buried under a woodpile, the F.B.I. would have had probable cause to forensically search the items to determine what was stored on the devices. The F.B.I. of course had much more than just that.” United States v. Laplante, 2016 U.S. Dist. LEXIS 56834 (N.D. Fla. Mar. 29, 2016),* adopted 2016 U.S. Dist. LEXIS 56819 (N.D. Fla., Apr. 28, 2016).*