United States v. Keck
United States Court of Appeals for the Eighth Circuit
2 F.4th 1085 (2021)
- Written by Tiffany Hester, JD
Facts
Swiss authorities informed the Federal Bureau of Investigation (FBI) that an Internet Protocol (IP) address linked to the residence of Matthew Fee and his fiancé Danika was distributing child pornography online. FBI agents went to the Fee residence and searched Matthew and Danika’s electronic devices with their consent. The devices did not contain any child pornography. Matthew and Danika told the FBI to investigate Danika’s father, Joseph Keck, Jr. (defendant), a truck driver who stayed at the Fee residence when he came to town. After learning that Keck had a prior child-pornography conviction, FBI agents waited at the Fee residence for Keck’s arrival. When Keck arrived in his van, FBI agents seized Keck’s electronic devices from Keck’s van without a warrant. Later, the FBI obtained a warrant to search the seized devices, finding child pornography and evidence of online distribution. The United States charged Keck with several child-pornography crimes. At trial, Keck moved to suppress the evidence obtained from his electronic devices, arguing that seizing the devices without a warrant violated the Fourth Amendment. The district court denied Keck’s motion. Ultimately, the jury found Keck guilty. Keck appealed.
Rule of Law
Issue
Holding and Reasoning (Grasz, J.)
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