Last week, the Ninth Circuit held in United States v. Wilson, No. 18-50440, 2021 WL 4270847, that a law enforcement officer violated a criminal defendant’s Fourth Amendment rights when he opened images attached to the defendant’s emails without a warrant, even though the images had previously been flagged as child sexual abuse materials (“CSAM”) by Google’s automated CSAM-detection software.  The court based its ruling on the private search exception to the Fourth Amendment, which permits law enforcement to conduct a warrantless search only to the extent the search was previously conducted by a private party.  Because no individual at Google actually opened and viewed the images flagged as CSAM, the court held that law enforcement “exceeded the scope of the antecedent private search,” thereby “exceed[ing] the limits of the private search exception.”  Op. at 20-21.

Because the Fourth Amendment applies only to searches conducted by the government, “a private party may conduct a search that would be unconstitutional if conducted by the government.”  Op. at 13.  If the private party later provides the fruit of that search to the government, the private search doctrine permits the government to repeat the search without a warrant.  In United States v. Jacobsen, 466 U.S. 109 (1984), the Supreme Court explained that a warrantless government search may be permissible under the private search doctrine if the search does not exceed the scope of an antecedent private search, in that the government “learn[s] nothing that had not previously been learned during the private search.”  Id. at 120.

Circuit courts are split on how to apply the private search doctrine in the context of CSAM reporting:  Federal law requires an electronic communication service provider with actual knowledge of a violation of child pornography laws to file a report with the National Center for Missing and Exploited Children (“NCMEC”), which forwards the report to law enforcement.  See 18 U.S.C. § 2258A.  Although providers are not required proactively to “search, screen, or scan” for CSAM on their platforms, id. § 2258A(f)(3), many choose to do so using automated CSAM-detection software.

Here, as the Ninth Circuit explained, Google’s report to NCMEC was “based on an automated assessment that the images [the defendant] uploaded were the same as images other Google employees had earlier viewed and classified as child pornography,” and NCMEC forwarded the report to the San Diego Internet Crimes Against Children Task Force.  Op. at 5.  Neither Google nor NCMEC personnel opened or viewed the reported images.  Id.  But when NCMEC forwarded the Google’s report to law enforcement, the investigating officer opened and viewed the images, without a warrant, and relied on descriptions of the images in applying for warrants to search Wilson’s email account and home, which ultimately led to his conviction.  Id. at 5-6.

The Ninth Circuit found a “large gap between the information in [Google’s report] and the information the government obtained and used to support the warrant application and to prosecute Wilson.”  Id. at 24.  The court considered the process by which Google’s automated software scanned for CSAM and concluded that, because “no identified Google employee ‘knew and could say’ what th[e] images showed,” and the report merely communicated that “the four images Wilson uploaded to his email account matched images previously identified by some Google employee at some time in the past as child pornography,” the government exceeded the scope of the private search by opening the email attachments and viewing the images without a warrant.  Id. at 22, 24.

The Ninth Circuit found the “critical fact” to be that no Google employee had viewed the images before the police officer did, relying on the “clear holding of Jacobsen” to conclude that “[w]hen the government views anything other than the specific materials that a private party saw during the course of a private search, the government search exceeds the scope of the private search.”  Id. at 28.

The court acknowledged that its decision “contribute[s] to a growing tension in the circuits about the application of the private search doctrine to the detection of child pornography.”  Id. at 31.  While the Tenth and Eleventh Circuits have adopted a similar interpretation of the private search doctrine, see United States v. Ackerman, 831 F.3d 1292 (10th Cir. 2016); United States v. Sparks, 806 F.3d 1323 (11th Cir. 2015), the Fifth and Sixth Circuits have concluded that a law enforcement officer may open and view images reported as CSAM without violating the Fourth Amendment, even if the reporting provider and NCMEC have not previously viewed these images, see United States v. Miller, 982 F.3d 412 (6th Cir. 2020); States v. Reddick, 900 F.3d 636 (5th Cir. 2018).  The U.S. Department of Justice has not yet indicated whether it will petition for rehearing, or seek Supreme Court review to address this circuit split.

 

Photo of Jim Garland Jim Garland

Jim Garland’s practice focuses on government investigations and enforcement matters, litigation, and cybersecurity. Recognized by Chambers USA as a leading practitioner in both the white collar and cybersecurity categories, Jim draws upon his experience as a former senior Justice Department official to advise…

Jim Garland’s practice focuses on government investigations and enforcement matters, litigation, and cybersecurity. Recognized by Chambers USA as a leading practitioner in both the white collar and cybersecurity categories, Jim draws upon his experience as a former senior Justice Department official to advise clients on sensitive, multidimensional disputes and investigations, often with national security implications. He previously served as co-chair of Covington’s “Band 1”-ranked White Collar and Investigations Practice Group and currently is a member of the firm’s Management and Executive Committees.

Jim regularly represents corporate and individual clients in government investigations and enforcement actions. He has successfully handled matters involving allegations of economic espionage, theft of trade secrets, terrorism-financing, sanctions and export control violations, money laundering, foreign bribery, public corruption, fraud, and obstruction of justice. He has particular expertise advising clients in connection with investigations and disputes involving electronic surveillance and law enforcement access to digital evidence.

Jim has substantial experience litigating high-stakes, multidimensional disputes for clients across a range of industries, including companies in the high-tech, financial services, defense, transportation, media and entertainment, and life sciences sectors. Many of his civil representations have substantial cross-border dimensions or involve parallel government enforcement proceedings in multiple forums.

In conjunction with his investigations and litigation practice, Jim regularly assists clients with cybersecurity preparedness and incident-response matters. He helps clients in assessing security controls and in developing policies and procedures for the protection of sensitive corporate data. He also regularly assists companies in responding to significant cybersecurity incidents, including in connection with criminal and state-sponsored attacks targeting customer and employee data, financial information, and trade secrets.

From 2009 to 2010, Jim served as Deputy Chief of Staff and Counselor to Attorney General Eric Holder at the U.S. Department of Justice. In that role, he advised the Attorney General on a range of enforcement issues, with an emphasis on criminal, cybersecurity, and surveillance matters.

Photo of Alexander Berengaut Alexander Berengaut

Alex Berengaut is a nationally recognized litigator and co-chair of Covington’s Government Litigation practice group. He has served as lead counsel in a range of commercial disputes and government enforcement proceedings, and currently represents several leading technology companies in litigation and compliance matters…

Alex Berengaut is a nationally recognized litigator and co-chair of Covington’s Government Litigation practice group. He has served as lead counsel in a range of commercial disputes and government enforcement proceedings, and currently represents several leading technology companies in litigation and compliance matters relating to data privacy, platform liability, artificial intelligence, and cybersecurity.

In recent years, Alex obtained a series of landmark victories against the federal government in bet-the-company disputes for technology clients. Alex represented TikTok in challenging the Trump Administration’s efforts to ban the app, delivering the winning argument that led the court to enjoin the ban hours before it was set to take effect. He also represented Xiaomi Corporation in challenging the Department of Defense designation that would have blacklisted the company from U.S. financial markets, delivering the winning argument that led the court to enjoin the designation, restoring $10 billion to Xiaomi’s market capitalization.

At the state level, Alex has successfully challenged unconstitutional state legislation and defended against state consumer protection actions. He obtained an injunction blocking Montana’s law banning the TikTok platform, and he secured the outright dismissal of multiple State AG consumer protection lawsuits relating to data privacy and security—a string of victories which resulted in Alex being recognized as Litigator of the Week

Alex has served as counsel to Microsoft Corporation in precedent-setting cases involving government surveillance issues, including Microsoft’s landmark challenge to the government’s attempt to compel disclosure of customer emails stored in Ireland using a search warrant; Microsoft’s First Amendment challenge in the Foreign Intelligence Surveillance Court to restrictions on disclosures about government surveillance; and Microsoft’s constitutional challenge to the statute that allows courts to impose gag orders on technology companies, resulting in nationwide reform of the government’s practices under the statute. 

 Alex maintains an active pro bono practice, focusing on trial-level indigent criminal defense and youth immigration matters. From 2017 to 2020, Alex represented the University of California in challenging the Trump Administration’s rescission of the Deferred Action for Childhood Arrivals (DACA) program, ultimately resulting in a 5-4 victory in the U.S. Supreme Court. See Department of Homeland Security, et al. v. Regents of the University of California et al., 140 S. Ct. 1891 (2020).

Photo of Megan Crowley Megan Crowley

Megan Crowley is a nationally recognized litigator who serves as co-chair of Covington’s Government Litigation practice. In her practice, Megan draws upon her experience at the U.S. Department of Justice where she litigated constitutional, statutory, and administrative law cases of national significance. In…

Megan Crowley is a nationally recognized litigator who serves as co-chair of Covington’s Government Litigation practice. In her practice, Megan draws upon her experience at the U.S. Department of Justice where she litigated constitutional, statutory, and administrative law cases of national significance. In addition to her federal practice, Megan has extensive experience challenging unconstitutional state actions, and defending against novel uses of state consumer protection laws by State Attorneys General.

Most recently, The American Lawyer named Megan “Litigator of the Week” for her successes in obtaining a preliminary injunction against the state of Montana’s ban of TikTok and securing the complete dismissal of a consumer protection lawsuit brought by the Indiana Attorney General. Megan also was a key member of the Covington team that represented TikTok in its successful challenge to the Trump Administration’s efforts to ban the app, as well as the team that represented Xiaomi Corporation in its successful challenge to the Department of Defense designation that would have banned the company from U.S. financial markets.

Megan has particular expertise representing technology companies in cutting-edge litigation relating to data privacy, and in 2022, she was named a Law360 Rising Star in Privacy. Megan also regularly represents clients in litigation under the Administrative Procedure Act, as well as disputes related to Section 230 of the Communications Decency Act, government demands for data under the Electronic Communications Privacy Act, and the First Amendment.

Megan maintains a robust pro bono practice, focused on civil rights litigation. She played a central role on the team representing the University of California in its challenge to the government’s rescission of the Deferred Action for Childhood Arrivals (DACA) program, obtaining a nationwide injunction and, ultimately, a 5-4 victory in the U.S. Supreme Court.

Photo of Chloe Goodwin Chloe Goodwin

Chloe Goodwin is a litigator and regulatory attorney focused on privacy and technology issues. She represents several leading technology companies in litigation and compliance matters relating to electronic surveillance, law enforcement access to digital evidence, cybersecurity, and data privacy.

Photo of Gaby Vasquez Gaby Vasquez

Gaby Vasquez is an associate in Covington’s Washington, DC office, where she works within the International Arbitration and White Collar practice groups. As a native Spanish speaker, Gaby is well-equipped to support clients and advise on matters related to Latin America and other…

Gaby Vasquez is an associate in Covington’s Washington, DC office, where she works within the International Arbitration and White Collar practice groups. As a native Spanish speaker, Gaby is well-equipped to support clients and advise on matters related to Latin America and other Spanish-speaking countries.

In her international arbitration practice, Gaby’s experience includes public international law and investor-state disputes. She also works on international human rights matters in her pro bono practice. In her white collar practice, Gaby works on complex anti-corruption investigations in various industries.