United States v. Cameron

699 F.3d 621 (2012)

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United States v. Cameron

United States Court of Appeals for the First Circuit
699 F.3d 621 (2012)

  • Written by Sharon Feldman, JD

Facts

The National Center for Missing and Exploited Children (NCMEC) was a non-profit organization involved in preventing the exploitation of children. Federal law required electronic-service providers to report violations of child-pornography laws to the NCMEC. NCMEC’s CyberTipline gave providers a way to report violations. Yahoo! was an electronic-service provider that allowed users to upload photographs to the Internet and share them with other users. Yahoo! received an anonymous tip about child-pornography images in a Yahoo! account under a particular username. Yahoo! never learned who supplied the tip. Pursuant to an established procedure for dealing with child-pornography reports, Yahoo! searched the account, discovered child-pornography images, and reported to CyberTipline that three accounts with different usernames had uploaded child-pornography images from the same IP address. The NCMEC sent those reports to the Maine state police’s Internet Crimes Against Children unit (ICAC) for investigation. The ICAC searched the home of James Cameron (defendant) and obtained documents from Yahoo! and Google pursuant to search warrants. Cameron was indicted for child-pornography-related crimes. Cameron’s motion to suppress the evidence resulting from Yahoo!’s searches was denied. Cameron was convicted. On appeal, Cameron argued that because Yahoo! was acting as an agent of the government when it searched his password-protected accounts for child pornography, his Fourth Amendment rights were violated, and the evidence of all subsequent searches executed by the ICAC should have been suppressed.

Rule of Law

Issue

Holding and Reasoning (Torruella, J.)

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