United States v. Huntzinger

69 M.J. 1 (2010)

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United States v. Huntzinger

United States Court of Appeals for the Armed Forces
69 M.J. 1 (2010)

Facts

Army Captain Aaron Miller received information that digital child pornography might be circulating within the barracks in his unit. Miller asked First Sergeant Joseph Goodwater to look into the matter. Goodwater spoke to the informant and a private about the matter. Based on these conversations and information that the private voluntarily provided from his computer, Goodwater believed that a search of the laptop owned by Specialist Robert Huntzinger (defendant) was likely to yield evidence relating to the investigation. Goodwater presented this information to Miller and asked for authorization to search for and seize Huntzinger’s laptop and any hard drives from Huntzinger’s barracks room. Miller authorized Goodwater to conduct the search and seizure. Goodwater entered Huntzinger’s room and seized his laptop and external hard drive. Miller searched the laptop and hard drive and discovered extensive evidence of child pornography on both devices. Huntzinger moved to suppress the evidence from the devices, arguing that the device search was unauthorized. Specifically, Huntzinger claimed that Miller’s involvement in the investigation meant that Miller was not a neutral party and, therefore, that Miller’s search authorization had been unlawful. Huntzinger’s motion was denied, and the evidence was used to convict Huntzinger. Huntzinger appealed the conviction.

Rule of Law

Issue

Holding and Reasoning (Effron, C.J.)

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