Hunter Vaughan Eure v. United States
FourthAmendment CriminalProcedure Privacy JusticiabilityDoctri
Whether an FBI agent can reasonably rely on the validity of a single warrant that authorizes a million searches of 100,000 different computers without describing any particular place to be searched?
QUESTION PRESENTED FOR REVIEW Under the Fourth Amendment, a warrant must “particularly describ[e] the place to be searched.” U.S. Const. amend. IV. In United States v. Leon, this Court held that the good-faith exception to the exclusionary rule does not apply when a warrant is “so facially deficient —i.e., in failing to particularize the place to be searched or the things to be seized — that the executing officers cannot reasonably presume it to be valid.” 468 U.S. 897, 923 (1984). Here, the FBI remotely searched thousands of personal computers around the world, including Mr. Eure’s. All of these searches were conducted pursuant to a single warrant. The warrant described the “place to be searched” as any computer that, in the future, accessed a certain website. But the warrant failed to describe any particular computer — by user, location, or otherwise. This single warrant authorized the FBI to conduct a million searches of 100,000 different computers. The question presented is: Whether an FBI agent can reasonably rely on the validity of a single warrant that authorizes a million searches of 100,000 different computers without describing any particular place to be searched? “i