Legal

Hello, You've Got Mail ... And Possibly Criminal Charges.

MayorBob.

Posted to Legal on Wed Mar 07, 2007 at 10:24:05 AM EST (promoted by port1080). RSS.

The case of the US vs. Kenneth Kelley presents us with troubling aspects.  The first aspect is that the doctrine of "reasonable doubt" may have been turned on its head.  The other aspect is that, based upon a decision by the Ninth US Circuit Court of Appeals, a person no longer need seek out a criminal activity to become the target of government prosecutors.  Now, even if you are just the unsolicited recipient of certain spam emails, you may find yourself a target.

Kelley, a 55-year-old writer from San Francisco, got caught up in the law when German investigators found his name on an email mailing list for a German child porn ring.  The Germans reported this to US authorities who determined that Kelley in fact had received emails containing child porn from the German site.  Federal agents seized Kelley's computer and found child porn images on the hard drive.  He contended a hacker must have maliciously placed the images on the hard drive.  A federal judge ruled the child porn images inadmissible as they had been obtained by a search for which the feds had no probable cause.  The judge ruled "people frequently receive unwanted e-mail and saying that authorities need to have evidence that the recipient intentionally violated the law in order to justify a search."  On to the Ninth Circuit.

In a 2-1 decision by a three judge panel (pdf doc), with retiring Justice Sandra Day O'Connor casting the deciding vote, the original decision was overturned.  Judge Pamela Rymer, writing the for the majority, said that even though the emails Kelley received were spam and therefore unsolicited, "the circumstances of their delivery indicated a fair probability" that he willingly received them.  She noted the emails were also found on the machines of other recipients and were sent to two user accounts Kelley maintained: "The reasonable inference ... is that Kelley was part of (a) network of persons interested in child pornography primarily involving young boys.  As a matter of practical, common sense, this is unlikely to occur without prior communication or connections."   Thus, in the mind of Judge Rymer, perish the thought of "reasonable doubt" that Kelley, who had no prior criminal record, never solicited the emails.

Dissenting Judge Sidney Thomas observed that previous rulings upholding computer searches required authorities offering some evidence about the computer's owner.  Thomas lamented, "lowering our standards of probable cause to permit government intrusion into private residences based solely on proof of mere transmittal of unsolicited email constitutes an unwarranted erosion of the Fourth Amendment."  The case is returned to trial court where Kelley could end up spending substantial time as a guest of the federal prison system and be tagged a sexual offender for the rest of his days.

Tags: edited by Port1080, written by MayorBob, edited by 1fastdog, Kenneth Kelley, child porn, probable cause, 4th Amendment, reasonable doubt (all tags)

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2

Interesting Case

wetkarma.

Wed Mar 07, 2007 at 11:24:23 AM EST

5.00 (interesting)

Couple points:

  1. I wonder if the fact that Kelley is gay played a role in how the court viewed this case? i.e. are gays perceived by the court as more probable to possess child porn?

  2. Reading the court opinion, it seems as if Kelley had marked the emails to "unread" status the evidence would have been tossed.

  3. I've been on the internet a while (early 90s), and never once have been mailed child porn. That said, I always like to take the internet out of a discussion and see what happens. If there had been evidence that Kelley had been snail mailed drugs/nuclear material, would a warrant have been issued?  

  4. The porn as described in the court document makes the document itself seem pornographic. Am I the only one who finds that ironic? Does erotic text involving children count as child porn?

Memory is a strange bell, jubilee and knell.

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Re: Interesting Case

ms sue.

Wed Mar 07, 2007 at 01:34:19 PM EST

none

The porn as described in the court document makes the document itself seem pornographic. Am I the only one who finds that ironic? Does erotic text involving children count as child porn?

That's really a stretch, unless the court document is intended to be sexually stimulating or to condone the depictions in question.

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Point 1 Unlikely

uncarved block.

Wed Mar 07, 2007 at 09:02:03 PM EST

none

   Given the vehemence with which law enforcement folks go after kiddie porn, I don't think gay or straight would make any difference. In other sex crime cases, the question would be a fair one, but not here, IMO.
   I'm not sure the snail mail vs e-mail comparison holds up. There's unsolicited mail, to be sure, but very little of it is illegal-- probably none, thinking about it. A notable percentage of unsolicited e-mail, OTOH, has the chance of being illegal in some jurisdictions- think bestiality porn, say- but they'll still get sent anyway. The economy of scale is too different, to put it another way; sending a million postcards would take a lot of time/money even if the postage is free, while sending a million spam e-mails can, AFAIK, be done with remarkably little investment in time or money. In the end, the defining factor would probably be the nature of the sender-- a spambot is one thing, but being on a personal list saved with "intent to distribute" is quite another.
    I can see some implications in the WoT coming from this case, though. Say an Islamic charity is exposed as being a front for terrorist fund raising-- does being on their e-mail list automatically give the Feds the right to investigate anyone/everyone on it after the fact? If not, then the entire mailing list would be off limits, and I can't see that sitting well with a Bush admin lawyer. Yet that would truly be a case of "guilty until proven innocent."
   One thing's for sure: folks had better start paying for better security, and making sure they know what's on their computers. A really vindictive soul with some technical savvy could ruin more than a few careers/reputations with this as a precedent, especially with something like child porn. It hasn't happened yet, but I can see it being a big problem in the future.

   (Oh, and on a site technical note: when I hit "reply", all the numbers in wetkarma's post disappeared, as well as the periods next to them. I don't have the slightest notion why, or if it means anything, but since TnT is still a work in progress, thought it worth mentioning. Firefox, FWIW, and I'm not sure which version.)

Ex ignorantia ad sapientiam; e luce ad tenebras

1

Yeah right...

rombuu.

Wed Mar 07, 2007 at 10:46:59 AM EST

none

...because I mean kiddie pr0n pushers really want to push out the spam, since they have don't have a a business that wouldn't lead them to pound me in the ass prison if one person they solicited who wasn't interested went to the authorities.

I find this argument slightly less believeable than Pete Townshend's.

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Re: Yeah right...

3fingerspointback.

Wed Mar 07, 2007 at 04:56:57 PM EST

4.50 (informative, astute)

Child porn rings don't spam?  It seems like a fake credit identity and a friendly offshore hosting company is all one needs to spam people with child porn and not get caught.

(is 3fingerspointback)

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Re: Yeah right...

Thalia.

Wed Mar 07, 2007 at 06:34:55 PM EST

none

Given that porn spam is between 8-10% of all spam, and that there have been documented cases of unsolicited porn spam including kiddie porn, I'm not sure where you're coming from.

Thalia

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Re: Yeah right...

rombuu.

Wed Mar 07, 2007 at 10:53:58 PM EST

none

Fine, fine..given they found 500 images on the guys computer even if he theoretically received some mysterious child pr0n spam, this is simple enough to figure out.  Are these images in the mail clients cache?  Or are they in a folder marked "do not open"?   Assuming these guys were spamming, why would the authorities overseas have marked this one guy out, since spammers usually send out millions of emails?  If they are that ignorant over there, wouldn't they have said "hey, here are 2.5 million people you need to check up on?"

And then finally they guy doesn't even claim these images came from spam... "hackers" placed those images on his computer.  I mean, sure, I found this photo Botticelli's Birth Of Venus on my HD the other day..damn hackers, always leaving pictures laying around.

The authorities aren't idiots.. some 9th circuit judge makes a dumb decision (surprise, must not have been any pressing Pledge of Allegiance lawsuits outstanding), and they get correctly smacked down.  

Oh well, I hear pedophiles don't have fun in the big house.  

8

You've got spam?

Lou.

Fri Mar 09, 2007 at 11:32:10 AM EST

none

I just got an email with the subject " afzayeshe ghad baraye baleghin !!! ba mojaveze rasmi !!!".  Do you think I should have pitched it like I did?  (Does anyone know what language that is?  Is it a language?")  

So I'm wondering, is it that hard to pick out spam?  Maybe I have too few friends, but I can usually tell by the subject line/sender whether something is spam or not.  Is it because I use yahoo for email?  I usually only get 2 or 3 spams a day (my bulk box on the other hand has almost 10k letters...which I don't see unless I go looking).  

Given my limited experience, I think this guy is full of it.

It's the end of the world as we know it, and I feel fine

9

Two Other User Accounts

Milo.

Sat Mar 10, 2007 at 11:18:52 AM EST

none

The thing that got me on this one was the part where the judge said, "the emails were also found on the machines of other recipients and were sent to two user accounts Kelley maintained".  I seems unlikely a spam bot would have managed to find three (two?) mail accounts to the same person -- at least for targetted spam like this.  I have several email accounts and I get viagra spam all day long.  I've never gotten a single child porn email.


The write-up suggests that this is some kind of attack on  "reasonable doubt."  But that has nothing to do with the issue at hand.  The argument isn't whether he was guilty, it was whether the cops had "probable cause" to search the computer.  The standard for probable cause, I think, is much lower than that of "guilt."


-milo

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