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Steven Lee Lindleyv.The State

CourtCourt of Appeals of Georgia
Docket No.A18A0299
DecidedMay 8, 2018
Reporter247 Ga. App. 719
JudgesCourt of Appeals of Georgia
Tags
CriminalCriminal LawCriminal ProcedureSex CrimesDigital EvidenceSufficiency of the EvidenceReversalTales From the CryptBroken Convictions
Case Summary

A jury convicted Steven Lee Lindley of fourteen counts of sexual exploitation of a child after investigators found fourteen illegal images on a Samsung tablet surrendered by a woman at a Braselton residence. The State introduced the images, search-history terms, and photographs of Lindley found on the device, but it did not establish that Lindley owned the tablet, lived at the residence, or downloaded or knowingly controlled the charged files. The Georgia Court of Appeals reversed. Georgia law requires proof that the defendant knowingly possessed or controlled the material, and circumstantial evidence must exclude every other reasonable hypothesis of guilt. The forensic examiner described the extraction as a data dump that did not establish who saved, viewed, or controlled the images. Evidence that Lindley appeared in photographs on the tablet and exchanged messages with the resident did not connect him to possession of the charged files. Because another person in the home could have owned the tablet or downloaded the images, the evidence was legally insufficient. The court reversed all fourteen convictions without reaching the statute-of-limitations or venue claims.

Opinion

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