D.Mont.: Dropbox conducted a private search finding CP

Dropbox found child porn in defendant’s account, and it reported to NCMEC. Dropbox conducted a private search. United States v. Balog, 2024 U.S. Dist. LEXIS 90179 (D. Mont. May 20, 2024).*

“Defendant argues that the search of his vehicle was improper because it did not fall in the curtilage of the home subject to the search warrant. Even assuming arguendo that defendant’s car was not within the curtilage of the home, we hold that Detective Gonzalez had independent probable cause to search defendant’s vehicle.” State v. Lamar Young, 2024 N.C. App. LEXIS 426 (May 21, 2024).*

There was an objective basis for the stop, so pretext fails. On reconsideration, what is complained about was already considered. United States v. Alexander, 2024 U.S. Dist. LEXIS 90122 (D.S.C. May 20, 2024).*

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