United States v. Pratt
United States Court of Appeals for the Fourth Circuit
915 F.3d 266 (2019)
- Written by Tiffany Hester, JD
Facts
During a sting operation in South Carolina, RM, a 17-year-old girl, told Federal Bureau of Investigation (FBI) agents that RM’s boyfriend, Samuel Pratt (defendant), brought RM from North Carolina to work as a prostitute. RM also stated that Pratt’s phone contained naked pictures of RM. After Pratt confirmed that his phone had naked pictures of RM, the agents seized the phone. Pratt did not consent to the seizure or give the agents the phone’s passcode. The FBI did not allow Pratt to keep any of the phone’s files. One month later, the FBI obtained a warrant to search the phone, finding naked pictures of RM and incriminating text messages. The United States indicted Pratt for child pornography and other offenses. At trial, Pratt moved to suppress the evidence found on the phone, arguing that the FBI’s delay in obtaining the search warrant was unreasonable. The government argued that the delay was justified because the agents were deciding whether to seek the warrant in North or South Carolina. The district court denied Pratt’s motion and admitted the phone’s contents into evidence. The jury convicted Pratt, and Pratt appealed.
Rule of Law
Issue
Holding and Reasoning (Diaz, J.)
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