While working as a life guard instructor, Matthew Mann covertly installed a video camera in a locker room in order to take footage of women changing their clothes.  After the camera was discovered and turned over to the authorities, police executed a search warrant at Mann’s home for “video tapes, CD’s or other digital media, computers, and the contents of said computers, tapes, or other electronic media, to search for images of women in locker rooms or other private areas.”  In connection with the search, police seized computers and an external hard drive from Mann.  Police later ran forensic software on this equipment that revealed the presence of child pornography, which formed the basis of a federal prosecution.

The district court denied Mann’s motion to suppress the images found on his hard drives.  Mann then pled guilty, but preserved the right to litigate his Fourth Amendment claim on appeal.  In United States v. Mann (No. 08-3041) (Rovner, J.), the Seventh Circuit affirmed.  Although the scope of the warrant was limited by its terms to a search for “images of women in locker rooms or other private areas,” the court held that police did not exceed the scope of the warrant when they collected and viewed Mann’s collection of child pornography.