Case Summaries: Fourth Circuit Court of Appeals (Dec. 2025)

This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during December 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here. Information omitted from search warrant application would not have defeated probable cause; denial of Franks motion affirmed U.S. v. Glass, 160 F.4th 563 (Dec. 2, 2025). In this case from the Western District of North Carolina, the defendant’s wife reported to law enforcement that the defendant’s phone contained “a massive amount” of child sexual abuse material (CSAM). She gave police the email address for the defendant’s Google Photos account and the likely password to that account. While speaking with a detective, she complained about the defendant and informed him that she hoped to soon divorce the defendant and obtain alimony payments. In a later meeting with a different police investigator, the woman stated that the defendant’s phone had at least 50 images of extremely graphic child pornography and that the defendant would recruit underage girls on social media to send him such images. During his investigation, the detective learned that the defendant’s wife had a pending charge for misdemeanor larceny and was being investigated for a separate incident of shoplifting. He also discovered that the defendant had been investigated three times before for child pornography offenses. In 2012, the defendant’s former wife reported seeing the defendant repeatedly view child CSAM. This led to two charges of forcible sodomy of a minor being [...]