Case Explained: United States of America v. Nicholas Joseph Peterson

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-17 The eighth-circuit affirmed the district court’s denial of Nicholas Peterson’s motion to suppress evidence seized during a federal search warrant execution. The court held that the state search warrants issued by Sarpy County judges in Nebraska for records held by Snap Inc. and Google in California were valid because Nebraska law expressly authorizes its county court judges to issue search warrants for service upon corporations located outside the state, specifically under Neb. Rev. Stat. § 29-812. The court rejected Peterson’s argument that these warrants violated the Fourth Amendment due to lack of territorial jurisdiction or non-compliance with Federal Rule of Criminal Procedure 41, noting that Rule 41’s limitations apply only to federal magistrate judges, not state judges who possess the authority granted by their respective states. Furthermore, the court ruled that even if the warrants were invalid, the evidence was admissible under the good-faith exception established in *United States v. Leon*, as it was objectively reasonable for the investigating officer to rely on the warrants issued by a state judge with apparent jurisdiction. Consequently, the evidence obtained from Peterson’s devices and his subsequent statements remain admissible, and his conviction and 262-month sentence stand. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.