Nearly 20-year sentence vacated by 4th Circuit

US v. Doyle: Doyle was convicted of receiving, possessing and mailing child pornography, and received a sentence of 235 months. On appeal, Doyle challenged the district court's decision to deny his motion to suppress. The Fourth Circuit disagreed with the district court that the good faith exception from Leon applied in this case, and held that the affidavit in support of the search warrant lacked the necessary information that the neutral magistrate could glean probable cause to support a search for child porn. The Fourth Circuit framed the question for review as not whether the warrant was simply deficient, rather whether the warrant was so deficient that relying upon it was unreasonable, thus precluding the operation of the good faith exception.