UNITED STATES v. HAAS

No. 19-4077.

986 F.3d 467 (2021)

UNITED STATES of America, Plaintiff-Appellee, v. Richard Todd HAAS, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: January 27, 2021.


Attorney(s) appearing for the Case

ARGUED: William Jeffrey Dinkin , WILLIAM J. DINKIN, PLC, Richmond, Virginia, for Appellant. Heather Hart Mansfield , OFFICE OF THE UNITED STATES ATTORNEY, Richmond, Virginia, for Appellee. ON BRIEF: G. Zachary Terwilliger , United States Attorney, Alexandria, Virginia, Brian R. Hood , Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Richmond, Virginia, for Appellee.

Affirmed in part, vacated in part, and remanded by published opinion. Judge Richardson wrote the opinion, in which Judge Wilkinson and Judge Harris concurred.


Richard Haas was convicted of attempted sex trafficking of a minor and three child-pornography offenses. He argues on appeal that the district court erred in denying a Franks hearing to challenge the veracity of law enforcement's declarations in two warrant affidavits. See Franks v. Delaware,

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