State v. Rykena

Citations

• 2025 Ohio 5136

Syllabus

Motion to suppress; Fourth Amendment; government actors; state actors; search; Snapchat; National Center for Missing and Exploited Children; private entity; electronic service provider; expectation of privacy; hash matching; child pornography. Affirmed. Trial court did not err when it denied appellant's motion to suppress evidence. The evidence in question was 12 images later determined to contain child pornography that appellant uploaded to his Snapchat account. The trial court did not err when it found that Snapchat was not a state actor when it conducted a hash-matching search of the uploaded images. Once he revealed the images to a third party, Snapchat, appellant no longer had an expectation of privacy in the content of the images. The National Center for Missing and Exploited Children conducted their own search that did not extend outside the scope of the search conducted by Snapchat.