Stephen Craig Ingram Missouri Cases

Stephen Craig Ingram appealed his conviction for possession of more than twenty still images of child pornography following a bench trial. He challenged the sufficiency of the evidence, arguing the date of possession was an element and that cache files should not count towards the image total. He also contended that evidence was unlawfully obtained in violation of the Fourth Amendment by Yahoo and NCMEC. The appellate court affirmed, holding that the date is not an element, cache files can be considered with corroborating evidence, and neither Yahoo nor NCMEC violated the Fourth Amendment as private parties or by acting within the scope of a private search or geolocating an IP address.