UNITED STATES v. SULLIVAN (2018)

Kevin Sullivan appeals his conviction for knowingly receiving at least one visual depiction of a minor engaged in sexually explicit conduct, in violation of 18 U.S.C. § 2252(a)(2), (b)(1). Using a “sniffer” device,¹ agents from the Georgia Bureau of Investigation found evidence of child pornography on electronic devices in Sullivan’s office at Emory University. Sullivan argues that the search warrant did not authorize the use of the sniffer device, that agents needed to obtain a second warrant before searching his office, and that the good faith exception to the warrant requirement does not apply. After careful review of the briefs and the record, and having the benefit of oral argument, we find no error.

AFFIRMED.

FOOTNOTES

1.   A “sniffer” is a tool that can be used for finding a specific Media Access Control address (an identifier unique to a particular device) if the suspect device is powered on and connected to a wireless network. The user of the sniffer inputs the MAC address of the device being sought, and the sniffer then listens for the signal between the device and the internet router over the wireless network. The sniffer detects the strength of the signal, which simply tells the user if the suspect MAC address is close by.

PER CURIAM: