State v. Peltier
The Second DCA reversed a trial court order suppressing child pornography evidence found on Peltier's devices, holding that the trial court misapplied the deferential 'substantial basis' standard of review to a magistrate's probable cause determination and effectively conducted an improper de novo review. The affidavit, which described specific hash-value matches to known child pornography and detailed depictions of sexual conduct/battery involving a child, provided a substantial basis for the magistrate's probable cause finding and was distinguishable from the conclusory affidavit condemned in Goesel v. State.
Key facts
- Peltier was charged with crimes related to child pornography found on his electronic devices following a search warrant.
- The trial court suppressed the evidence, finding the warrant affidavit lacked sufficient probable cause and was conclusory.
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Why it matters
This opinion clarifies and reinforces the deferential 'substantial basis' standard trial courts must apply when reviewing a magistrate's probable cause determination in warrant cases, correcting a trend toward de novo… — full analysis with a trial
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