Kentucky Supreme Court

Commonwealth of Kentucky v. Kevin Master

December 19, 2024

Summary

The Court affirmed the Court of Appeals’ determination that the search-warrant affidavit did not establish probable cause to search Master’s residence and electronic devices for child pornography. The affidavit relied on the purchase of a then-legal child sex doll and generalized law-enforcement experience, but contained no individualized facts connecting Master to child pornography or establishing the required nexus to the place searched. The Court remanded for an evidentiary hearing on whether the warrant was nevertheless executed in good faith.