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U.S. v. PRATT

No. 17-4489.

915 F.3d 266 (2019)

UNITED STATES of America, Plaintiff-Appellee, v. Samuel PRATT, a/k/a Promise, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: February 8, 2019.

Attorney(s) appearing for the Case

ARGUED: David Bruce Betts , LAW OFFICES OF DAVID B. BETTS, Columbia, South Carolina, for Appellant. James Hunter May , OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee. ON BRIEF: Beth Drake , United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee.

Affirmed in part, vacated in part, and remanded by published opinion. Judge Diaz wrote the opinion, in which Judge Motz and Judge Agee joined.

Samuel Pratt was convicted of eight counts related to sex trafficking and child pornography. He appeals on two grounds. On the first ground, we hold that the district court should have suppressed evidence from Pratt's cellphone. That error was not harmless because the remaining evidence does not satisfy the elements of the two...

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