The government did not show probable cause to believe that child pornography was on defendant’s electronic devices. The officer’s experience is one thing, but no facts suggest that defendant “is a collector of child pornography.” The record is inadequate to determine whether the good faith exception should apply, and a hearing will be scheduled. United States v. Lipscomb, 2019 U.S. Dist. LEXIS 118365 (E.D. Va. July 16, 2019),* later opinion United States v. Lipscomb, 2019 U.S. Dist. LEXIS 146767 (E.D. Va. Aug. 28, 2019) (reported here) (GFE shown outside the four corners of the affidavit).
“This is a child-exploitation case. Principally at issue is whether agents exceeded the scope of a warrant authorizing the search of a ‘residence’ when they searched a ‘shed-like structure’ on the property but not mentioned in the warrant. The Court holds that they did not and that, in any event, the good-faith exception controls.” United States v. Babin, 2019 U.S. Dist. LEXIS 118357 (M.D. La. July 16, 2019).*