{"id":64133,"date":"2026-05-30T05:09:16","date_gmt":"2026-05-30T10:09:16","guid":{"rendered":"https:\/\/fourthamendment.com\/?p=64133"},"modified":"2026-05-30T05:09:16","modified_gmt":"2026-05-30T10:09:16","slug":"ca9-when-a-digital-computer-search-reveals-a-cp-hash-value-officer-doesnt-have-to-see-image-to-have-pc","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=64133","title":{"rendered":"CA9: When a digital computer search reveals a CP hash value, officer doesn&#8217;t have to see image to have PC"},"content":{"rendered":"\n<p>A digital computer search that produces an image with a hash value that matches known child pornography is probable cause without the officer even seeing the image. <a href=\"https:\/\/cdn.ca9.uscourts.gov\/datastore\/opinions\/2026\/05\/26\/24-6689.pdf\">United States v. Johnsen<\/a>, 2026 U.S. App. LEXIS 14893 (9th Cir. May 26, 2026).<\/p>\n\n\n\n<p>The state court proceedings below didn\u2019t result in a final judgment, so there\u2019s no issue preclusion. On qualified immunity, the court can\u2019t say the arrest was with probable cause based on this record, and it\u2019s remanded. Martinez v. City of Pheonix, 2026 U.S. App. LEXIS 14874 (9th Cir. May 26, 2026).*<\/p>\n\n\n\n<p>Defendant was stopped for a traffic offense, and the officer decided to call for a dog sniff which occurred almost immediately, within a minute and before paperwork was done. Unprompted, she admitted to a small amount of meth in the car [which was essentially treated as triggered by the dog being there]. The search was legal under Rodriguez. Davis v. Commonwealth, 2026 Va. App. LEXIS 293 (May 26, 2026).*<\/p>\n","protected":false},"excerpt":{"rendered":"<p>A digital computer search that produces an image with a hash value that matches known child pornography is probable cause without the officer even seeing the image. United States v. Johnsen, 2026 U.S. App. LEXIS 14893 (9th Cir. May 26, &hellip; <a class=\"more-link\" href=\"https:\/\/fourthamendment.com\/?p=64133\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[12,27,126,20,40],"tags":[],"class_list":["post-64133","post","type-post","status-publish","format-standard","hentry","category-computer-searches","category-dog-sniff","category-issue-preclusion","category-probable-cause","category-qualified-immunity"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64133","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=64133"}],"version-history":[{"count":1,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64133\/revisions"}],"predecessor-version":[{"id":64134,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64133\/revisions\/64134"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=64133"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=64133"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=64133"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}