FACTS
After the government discovered financial ties between William Meyer and individuals in the Philippines who were livestreaming sex acts involving children, two federal agents visited Meyer at his home. After the agents knocked on his door, Meyer insisted on speaking with them outside, so the agents spoke with Meyer in their car. During their conversation, Meyer revealed a number of facts that stirred the agents’ suspicion, including that Meyer had personal and financial ties to the individuals involved in the abuse. When Meyer admitted that he used a computer and cell phone to contact them, the agents asked Meyer if he would be willing to turn those devices over to them for an examination. Meyer told the agents that he was willing to turn them over later, after he had a chance to “check [his] email and stuff.” Once the agents expressed concern that a delay would give him a chance to erase what was on them, Meyer still refused to consent, claiming that his house was “a mess” and “not . . . in any condition to entertain people.” Then, after the agents mentioned the possibility of getting a warrant, Meyer suggested that the agents “come back later.” One of the agents told Meyer that if they obtained a warrant, they would not tell him beforehand when they were coming to execute it. A short time later, Meyer went back inside his house.
Concerned that Meyer would destroy evidence if they waited any longer, one of the agents called a prosecutor for advice on whether “an exigent circumstance existed.” When he was told that it did, the agents again knocked on Meyer’s door, searched his home for electronic devices, and seized two computers, a cellphone, and a hard drive. Afterward the agents obtained a warrant to search the devices seized from Meyer’s home. The search revealed child pornography videos and evidence that Meyer had sent money in exchange for the videos.
After the district court denied Meyer’s motion to suppress the evidence discovered on his devices, he plead guilty to one count of sexual exploitation of children. On appeal, Meyer claimed that the agents’ warrantless entry into his home violated the Fourth Amendment.