United States v. Brown, No. 11-5048 (4th Cir. 2012)
Annotate this CaseDefendant appealed his conviction and sentence for a child pornography offense. The court held that law enforcement officers had probable cause to enter into the property at issue and their subsequent inquiries regarding laptop computers were also lawful and proper. Therefore, the court rejected defendant's contention of a Fourth Amendment violation. The court also held that the district court did not abuse its discretion by denying defendant's motion to dismiss and striking the lesser-included offense of possession of child pornography. Accordingly, the court affirmed the judgment.
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