We use both our own and third-party cookies for statistical purposes and to improve our services. If you continue to browse, we consider that you accept the use of these.
  • Celebrating 20 Years of Training Excellence 2004-2024

Private Searches

It would be a shame to have the evidence suppressed on a case you are investigating because you didn’t take the time to be careful. Be Careful. Take TIME. Get a Search Warrant!!!


In People v. Evans, 2014 DJDAR 13573, the court examined a case where a computer repairman viewed images on a computer brought to him for service by the defendant. The computer repairman (Sage) viewed images that appeared to him to be underage girls engaging in sexual activity. Sage called the police. An officer responded to the computer repair shop and viewed the photos that Sage viewed. The officer stated that although the photos he viewed were posing in a sexual manner none were engaging in sexual activity or simulating sexual activity. The officer considered none of the images pornographic. The officer asked Sage whether he could search and look at anything else on the computer. Further examination revealed other videos that Sage could not open. Sage placed those videos on a thumb drive that were subsequently opened at the police department. Those videos depicted juveniles engaging in sexual activity.


Defendant argued that he had a reasonable expectation of privacy in his computer and the government argued he forfeited that expectation when he brought the computer to the shop to be fixed.


The court went through a great deal of analysis to come to a simple conclusion: In the search of a a computer disc, external drive, thumb drive, smart phone, etc. officers viewing of items following a search by a private citizen does not constitute a search provided that officers confine their search to that already done by the private citizen.

The court further held that police “exceed the scope of a private search when they examine a closed container that was not opened by the private searchers unless officers are “substantially certain” based on the statements of the private searchers, or their training and experience contraband will be found there. If officers cannot show they were substantially certain of the contents of the closed container before they opened it, the contents will be suppressed. An interesting side note to the consent issue, the court held Sage was directed by the officer to make copies of the files at issue. An analysis of the case law suggests that what an officer says will make a huge difference in the outcome of a consent case. Request, do not demand, compliance with what you as a reasonable officer wants and the result may be different.


After a civilian has reported seeing illegal material on a computer, view one or two images, and then request a search warrant.


  • This was, by far and away the best training I have received in 15 plus years of Law Enforcement. The instructors are experienced, engaging, articulate, and very entertaining. I will be recommending this training to multiple agencies.

    —Mark Paynter, Oregon DOC
  • This was, by far, one of the most useful training classes I've attended since becoming an investigator.

    —Steven Aiello, Antioch Police Department
  • Your training gave me the confidence and tools to interview the suspect for over 5 hours and to bring a closure to the case.

    —Daniel Phelan, San Jose Police Department
  • Instructional style is engaging and highly effective.

    —George Laing, Fire Prevention Captain, Investigator
  • I highly recommend this training for any Probation staff who have the necessity to interview/interrogate individuals for investigation purposes.

    —R. Bret Fidler, Santa Clara County Probation Department
  • This training provided the useful tools necessary for assessing the veracity of a suspected child abuser, which goes a long way in helping to protect children.

    —Sunny Burgan, MSSW, LCSW, Social Work Supervisor, Santa Clara County DFCS
  • It not often that you go to a training that you really, really want to pay attention to. Because of the high quality information and style of presentation, I knew that if I looked away I was going to miss out.

    —Quinten Graves, Oregon State Police
  • Incredible training with amazing real world instruction. I have been taking law enforcement classes for over 30 years and by far this is the best presented and most useful.

    —Det. Brian Dale, Portland Police Bureau
  • Effective teaching teams! The presentation of the material was consistently interesting, and intelligent without being too intellectualized.

    —Michele Keller, Deputy Probation Officer, County of Alameda
  • Your training has made the greatest and most direct impact on my assignment of any training class that I've taken.

    —Ken Gelskey, National City Police Department
  • This training by far has been the most informative and most effective I've attended. The instructors engaged the students in a manner that made me want to speak my opinion, ask questions, and participate.

    —Julio Ibarra, Merced County Sheriff’s Office
  • The information presented was highly relevant to my job and was presented in a manner that was organized and very easy to digest.

    —Michael McGarvey, California State Prison, San Quentin
  • I will continue to use and pass on this information because I really believe in the instructors and their approach.

    —Kimberly Meyer, Washoe County Sheriff's Department