U.S. v. Reichling

Dist. Ct. did nor err in denying defendant’s motion to suppress seizure of VHS tape containing pictures of child pornography, where affidavit submitted in support of search warrant indicated that defendant and minor communicated via their cell phones, and that minor sent to defendant naked pictures of herself in various sexual positions. While defendant argued that police should not have seized VHS tape since affidavit indicated that pictures were relayed through cell phones and since there was no indication that defendant had transferred photos to any other device, judge who issued warrant could properly find that images sent via cell phones could be transferred to other storage devices such as videotapes in view of large number of images in question. Fact that agent preparing affidavit failed to mention possibility of said transfer did not invalidate warrant.