United States v. Terry Christensen

MEMORANDUM

Defendants Terry Christensen, Anthony Pellicano, Mark Arneson, Rayford Turner, Kevin Kachikian, and Abner Nicherie appeal their criminal convictions stemming from a widespread criminal enterprise offering illegal private investigation services in Southern California.

The facts of this case have been related in detail in a concurrently filed opinion that discusses some of the issues raised on appeal and explains why some of the counts of conviction are reversed. See United States v. Christensen, 801 F.3d 970 (9th Cir.2015). In this memorandum disposition, we affirm as to all remaining issues.

I. Probable Cause to Support November 2002 Warrant

Christensen and Pellicano argue that the November 2002 warrant was invalid because the application for it did not include evidence to establish probable cause for a necessary element of a Hobbs Act violation: that Pellicano would obtain money or property from Busch by threatening her. This court has previously held that even if the magistrate judge was wrong about the Hobbs Act elements, the officers were entitled to rely on the November 2002 warrant under the good faith exception to suppression. United States v. Pellicano, 135…