The Sixth Circuit held that a suspected marijuana grower's consent to a search of his residence for "other material or records pertaining to narcotics" allowed the police to search a thumb drive connected to his laptop, on which they found child pornography. In affirming the denial of the defendant's motion to suppress, the court reasoned that because marijuana growers often keep spreadsheets and images of their plants on their computers, the search was within the scope of the defendant's consent.