United States v. Daigle

── United States v. Daigle ── Court: Court of Appeals for the First Circuit Date: June 10, 2026 Category: General United States Court of Appeals For the First Circuit No. 24-1889 UNITED STATES OF AMERICA, Appellee, v. ROBERT DAIGLE, Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Nathaniel M. Gorton, U.S. District Judge] Before Barron, Chief Judge, Lipez and Rikelman, Circuit Judges. Zainabu Rumala, Assistant Federal Public Defender, for appellant. Randall E. Kromm, Assistant United States Attorney, with whom Leah B. Foley, United States Attorney, was on brief, for appellee. June 10, 2026  RIKELMAN, Circuit Judge. Robert Daigle appeals the denial of his motion to suppress evidence discovered in a search of his home. According to Daigle, the government did not establish probable cause to believe that child pornography would be found on his home computer at the time of the search. The district court concluded otherwise, relying on facts showing that, nine months earlier, a computer with an IP address tied to Daigle's residence had logged requests on a specialized network for three electronic files that contained child pornography, all within ten minutes. We conclude that these facts were sufficient to meet the probable cause standard and thus affirm. I. BACKGROUND A. Relevant Facts This case arises from a decade-long investigation by law enforcement into Freenet, a peer-to-peer network that "allows users to anonymously share files, chat on message boards, and access websites within the network." To put the legal issues in context, we recount the basic mechanics of Freenet, as well as the events that led the government to Daigle. We draw the facts from the search warrant affidavit submitted in this case by Special Agent Brian O'Sullivan of the Federal Bureau of Investigation (FBI). - 2 -  1. The Mechanics of Freenet To access the Freenet network, "a user must first download the Freenet software, which is free and publicly available." A computer running the Freenet software "connects directly to other computers running Freenet, which are called its 'peers.'" When a user installs Freenet, they "agree[] to provide to the network a portion of the storage space on [their] computer hard drive, so that files uploaded by Freenet users can be distributed and stored across the network." Once a user uploads a file to Freenet, "the software breaks the file into pieces (called 'blocks') and encrypts each piece." These encrypted blocks are then "distributed randomly" and stored by peer computers. Freenet creates an "index piece," which contains a list of all the file's blocks, and assigns a "unique key -- a series of letters, numbers and special characters" -- to the file. To download a file on Freenet, a user must have the key associated with that file. When a user tries to download a file, Freenet requests that file's blocks from other computers running the Freenet software (the peers). Instead of requesting all the blocks from one peer, Freenet "divide[s] up" the block requests "in roughly equal amounts among the user's peers." If a peer computer does not have the requested blocks, that peer will divide up the request and ask additional peers for the missing blocks, - 3 - and so on. Critically, just because a user requests a file does not guarantee that t