N.D.Ga.: The question is PC for a SW, not what else officers could do to get more information; if they have PC, that’s all that’s required

The fact officers could have done more to validate their suspicions about a Facebook picture and who the child was and defendant and child pornography allegedly involving the same child, it isn’t constitutionally required if probable cause exists. United States v. Nichols, 2016 U.S. Dist. LEXIS 68987 (N.D. Ga. May 26, 2016):

However, “[c]ourts have uniformly rejected defense arguments that further investigation should have been conducted to either corroborate or to negate the information in the affidavit or else the search warrant lacks probable cause.” United States v. Lebowitz, 647 F. Supp. 2d 1336, 1347 (N.D.Ga. 2009). Instead, “the Court must evaluate probable cause based on what information was actually presented to the magistrate, not based on what information could have been presented after further investigation, but was not.” United States v. Adigun, 2011 U.S. Dist. LEXIS 60310, 2011 WL 2194253, at *13 (N.D.Ga. May 4, 2011). Applying this standard to the present case, Judge Vineyard correctly determined that the search warrant was supported by probable cause to believe that evidence of a crime would be found at the residence searched.