Voyles V. the State of Texas Court Case Summary
In 2000, the Arlington Police Department received information stating that Earnest Leon Voyles had exchanged emails that contained sexual content with a fifteen year old girl from London, England. According to this informant the fifteen year old girl, “Amy Chang”, had been solicited for sex by Voyles and had arranged to meet with her in London to engage in a sexual relationship.
Sergeant James Crouch of the Arlington Police Department was unsuccessful in contacting “Amy Chang” to verify the arrangement but was not successful, however, he was successful in verifying that Voyles was working as a teacher at a junior high located in Arlington, Texas. Working with the information provided by the informant, Sergeant Crouch, sent an email to Voyles describing himself as a fifteen year old girl named “C. J. Best” on December 28, 2000. In this email “C. J.
Best” told Voyless that she was looking for a new chat buddy and that she had gotten his address through some friends and that she lived in Forth Worth, Texas. About two and a half hours later Voyles responded to the email indicating that he was interested in being chat buddies with “C. J. Best. ” On January 19, 2001, after several emails were exchanged between Voyles and “Best” Sergeant Crouch obtained search warrants for Voyles home and work computers where the Arlington Police Department found and “seized child pornography off the hard drives of each unit.
Voyles was charged and indicted for possession of child pornography which is a third degree felony. In 2002, alleging that the evidence that the Arlington Police Department obtained from both his home and work computers was inadmissible claiming an unlawful search and seizure in violation of the First and Fourth Amendments to the United States Constitution and article I of the Texas Constitution, Voyles filed a motion to suppress.
The Fourth Amendment and Article I of the Texas Constitution provides that a defendant has standing to challenge the admission of evidence obtained by an intrusion by the government or a private individual only if he had a legitimate expectation of privacy in the place invaded. Although the trial court granted Voyles’s motion to suppress all of the evidence from his home computer they denied his motion to suppress the evidence obtained on his work computer; stating that the evidence was admissible because Voyles “had no reasonable expectation of rivacy in his work computer. ”
Although Voyles stated that he took precautions to prevent others from accessing or viewing items on his work computer the State argued that he had no expectation of privacy because the computer was owned by the school district, was located in a public classroom that was designed not only for teaching students, but was designed to be available for use by substitute teachers.
The Texas Court of Criminal Appeals has articulated several factors as relevant in determining if the defendant’s subjective expectation is recognized as objectively reasonable, most notably, “whether he had complete dominion or control and the right to exclude others” from the information on the computer and the use of the computer. As stated earlier, because the computer was owned by the Arlington School District, Voyles clearly did not have complete dominion or control over the computer or the files located on the hard drive of the computer.
The court also brought up the fact that the computer was placed in the classroom by the school district for classroom laboratory work related purposes that allowed Voyles to teach his students about computers; not for Voyles’s personal or private use. Considering all of this information Voyles failed to establish a reasonable expectation of privacy regarding his work computer and the data stored in it.
He could not contest the admission of the evidence seized from his work computer or the affidavit executed to support the search warrant that authorized the search of his school computer; a computer that despite not allowing someone else to use or even by placing a password on could still be used by students or substitute teachers through the assistance of the Information Technology Department.