FBI's Use of Wireless-Tracking Software Does Not Trigger 4th Amendment, Appellate Court Rules
The ruling from the U.S. Court of Appeals for the Ninth Circuit continues to sketch the limits of the Fourth Amendment in digital searches.
November 04, 2019 at 07:10 PM
3 minute read
A federal appellate court further ironed out the reach of the Fourth Amendment in today's digital age, ruling the protection from unreasonable search and seizures does not apply to law enforcement's use of wireless-tracking software through a third-party internet router.
A panel for the U.S. Court of Appeals for the Ninth Circuit ruled Monday that the FBI's usage of software called Moocherhunter to find device addresses linked to child pornography did not constitute an unreasonable search under the Fourth Amendment since the suspect was pirating his neighbor's internet.
The defendant, Alexander Nathan Norris, allegedly used an unauthorized connection to his neighbor's wireless router to distribute child pornography through a peer-to-peer file-sharing network. The FBI deployed Moocherhunter, a software program aimed at identifying network trespassers without directly accessing any devices, via Norris' neighbor's network. Since the officers did not "physically intrude" on his residence, the act is not covered by constitutional protections, the court ruled.
Judge Johnnie Rawlinson, who wrote the opinion on behalf of Judges Mary Schroeder and Diarmuid O'Scannlain, compared the FBI's actions in the case to observing the source of loud music from within an apartment complex.
"Although the music is produced within the apartment, the sound carries outside the apartment," Rawlinson wrote. "Just as no physical intrusion 'on constitutionally protected areas' would be required to determine the source of the loud music, no physical intrusion into Norris's residence was required to determine the strength of the wireless signal emanating from the devices in his apartment."
The court further ruled that the Fourth Amendment did not apply because Norris co-opted the neighboring apartment's wireless network. The panel cited a Third Circuit decision that also used Moocherhunter: United States v. Stanley. The defendant in that case also accessed child pornography through a third-party router, and the court decided that "while Stanley may have justifiably expected the path of his invisible radio waves to go undetected, society would not consider this expectation legitimate given the unauthorized nature of his transmission."
The Ninth Circuit largely agreed with the Stanley ruling, arguing that Norris forfeited his Fourth Amendment right when he illegally accessed the wireless connection.
"Indeed, it strains credulity to suggest that society would be prepared to recognize an expectation of privacy as reasonable when an individual gains access to the internet through the unauthorized use of a third-party's password-protected router located outside his residence," Rawlinson wrote.
Norris' attorney at appeal, John Balazs of The Law Office of John Balazs, declined to comment.
The Department of Justice was represented by Assistant U.S. Attorneys Matthew Morris; Shelley Weger; Appellate Chief Camil Skipper; and McGregor Scott from the Eastern District of California. They did not immediately respond to a request for comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View All'Serious Disruptions'?: Federal Courts Brace for Government Shutdown Threat
3 minute readAn ‘Indiana Jones Moment’: Mayer Brown’s John Nadolenco and Kelly Kramer on the 10-Year Legal Saga of the Bahia Emerald
Will Khan Resign? FTC Chair Isn't Saying Whether She'll Stick Around After Giving Up Gavel
Trending Stories
- 1Call for Nominations: Elite Trial Lawyers 2025
- 2Senate Judiciary Dems Release Report on Supreme Court Ethics
- 3Senate Confirms Last 2 of Biden's California Judicial Nominees
- 4Morrison & Foerster Doles Out Year-End and Special Bonuses, Raises Base Compensation for Associates
- 5Tom Girardi to Surrender to Federal Authorities on Jan. 7
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250