State v. McNeela
The Second DCA reversed an order suppressing evidence obtained via a search warrant for computer equipment, holding that a warrant affidavit describing Microsoft's report to NCMEC that a user uploaded child pornography images, combined with detailed descriptions of the images and the defendant's admissions, established probable cause. The court held that Microsoft, like other internet service providers, qualifies as a presumptively reliable citizen informant, and that detailed graphic descriptions of the images themselves (rather than conclusory assertions) satisfied the magistrate's need for sufficient information to independently assess probable cause.
Key facts
- State charged defendant McNeela with child pornography offenses based on evidence obtained via a search warrant for computer equipment.
- Microsoft reported to the National Center for Missing & Exploited Children (NCMEC) that a user uploaded child pornography images; the warrant affidavit detailed the reported images and included defendant's prior admissions that he lived at the residence and was the primary computer user.
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Why it matters
This opinion reinforces and extends Woldridge's holding that ISPs and tech companies like Microsoft are treated as presumptively reliable citizen informants in child pornography investigations, strengthening the State's… — full analysis with a trial
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