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United Statesv.Brillhart

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.24-13226
Decided2026-07-09
ReporterNo. 24-13226 (11th Cir. 2026)
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
Eleventh CircuitFourth AmendmentPrivate Search DoctrineElectronic EvidenceChild PornographyDouble JeopardySentencing Guidelines
Case Summary

Brillhart challenged child-pornography convictions and related sentences after Google’s automated hash-matching system identified a file and disclosed it for investigation. The Eleventh Circuit held that Google’s automated comparison was a valid private search and that law enforcement did not exceed its scope by reviewing the matched file. It also rejected Brillhart’s double-jeopardy, evidentiary, sufficiency, jury-instruction, and psychological-evaluation claims. But the district court erred in applying the Guidelines’ pattern-of-activity enhancement. The court affirmed the convictions and most rulings, vacated the sentence in part and remanded for resentencing, and dismissed supervised-release issues that had become moot.

Opinion

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