Facebook is not a government actor, even if NCMEC is under the Tenth Ciruit’s Ackerman. United States v. Sykes, 2021 U.S. Dist. LEXIS 9580 (E.D. Tenn. Jan. 19, 2021).
46 days from a child pornography download by the government to issuance of a search warrant wasn’t stale. United States v. Fiore, 2021 U.S. Dist. LEXIS 9524 (D. Vt. Jan. 19, 2021).*
The dissent counters that the district court didn’t “properly engage” the protective sweep and consent on the totality. United States v. Cousins, 2021 U.S. App. LEXIS 1365 (6th Cir. Jan. 19, 2021).*