Commonwealth v. Dunn

Summary

The court held that the search warrant affidavit established probable cause to search the defendant’s residence and electronic devices, even though the affidavit did not attach the images and its descriptions of their focal points were incomplete. The affidavit’s descriptions, the provider’s personal observation, the recognized hash values, and the defendant’s relevant prior history collectively supplied a substantial basis for the warrant. The court also held that the defendant failed to make the required preliminary showing of intentional or reckless falsity to obtain a Franks hearing. The court affirmed both denials.