OH5: A mandated CP reporter isn’t a state actor

The fact AOL is a mandated reporter of child pornography that it discovers does not make AOL a state actor in its discovery of child pornography. Thus, AOL’s search of the email was a private search. Then there was a search warrant issued. In any event, the officers acted in good faith. State v. Ryan, 2018-Ohio-4739, 2018 Ohio App. LEXIS 5064 (5th Dist. Nov. 28, 2018).

The USMJ’s finding stated that defendant’s trash containers were off the curtilage at the time of the trash pull. In addition, the trash pull occurred just before that day’s trash collection by the city. United States v. Warren, 2018 U.S. Dist. LEXIS 199913 (E.D. N.C. Nov. 27, 2018).*

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