Jul. 12, 2023 – People v. Wadleigh (1st Dist., Div. 4, A165017)

The Court of Appeal affirms the denial of defendant’s motion to suppress, even though the warrant application did not include the suspected child pornography images and included an inaccurate description of one of the images. The court finds that the officer’s accurate depiction of most of the images, along with other factors, was enough to establish probable cause. The court notes, however, that “officers should, whenever possible, include images of suspected child pornography in warrant applications, particularly where, as here, a subjective evaluation is necessary to determine whether the images’ content is prohibited.”