Bates v. State
The First DCA affirmed Bates's convictions for capital sexual battery, molestation, video voyeurism, and 50 counts of child pornography possession. The court rejected his unpreserved challenge to disjunctive charging language, upheld denial of his motion to suppress laptop evidence (finding he lacked standing and, alternatively, that officers reasonably relied in good faith on the search warrant), and found no fundamental error in a brief trial reference to additional uncharged images given 50 images were already properly in evidence.
Key facts
- Bates was charged with capital sexual battery, moleavgust, video voyeurism, and 50 counts of child pornography possession; the trial court denied his motion to suppress a laptop seized from his home.
- Officers obtained a search warrant for Bates's home based on a description of a home camera system and victim statements about photographed abuse; the laptop was seized and searched pursuant to that warrant.
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Why it matters
This opinion offers useful modern guidance on applying the good-faith exception and probable-cause nexus requirements to warrants seeking computer evidence tied to home surveillance systems, updating older analog-era… — full analysis with a trial
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