United States v. Lamarcus Thomas
Court of Appeals for the Fourth Circuit
1Opinion of the Court
PAMELA HARRIS, Circuit Judge:
Detective Charles Coleman arrested LaMarcus Thomas on charges of aggravated sexual battery, and seized a cell phone from Thomas during a search incident to the arrest. After Coleman obtained a warrant to search the phone, authorities discovered sexually explicit images and videos involving children.
Charged with producing child pornography, Thomas moved to suppress that evidence, arguing that the affidavit submitted with Coleman's warrant application was insufficient to establish probable cause for the search. The district court agreed that the affidavit was…
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