Petition for Writ of Certiorari — Christopher Todd Boudreau, Petitioner v. United States

No. ______

__________________________________________________________________

IN THE

SUPREME COURT OF THE UNITED STATES

__________________________________________________________________

OCTOBER TERM 2025

__________________________________________________________________

CHRISTOPHER TODD BOUDREAU,

Petitioner,

v.

UNITED STATES OF AMERICA,

Respondent.

__________________________________________________________________

PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

__________________________________________________________________

David A. Mattingley

DISTEFANO & MATTINGLEY, PLLP

423 First Ave. East

Po Box 2341

Kalispell, MT 59903

(406) 300-2343

Email: david@nwmontanalaw.com

Counsel of Record

SUBMITTED: April 20, 2026

i

QUESTION PRESENTED

Whether the Fourth Amendment permits a warrant to authorize a search

of a residence and the seizure of all electronic devices within it based

on generalized assumptions about digital evidence, where the

government has already obtained the device used in the alleged offense

and identifies no case-specific facts linking additional devices to the

home.

ii

LIST OF PARTIES

While the caption of the case contains the names of all the parties, the parties to the

proceeding are:

The Petitioner is Christopher Todd Boudreau, an individual. Petitioner was the

defendant in the federal district court and appellant in the Ninth Circuit.

The Respondent is the United States of America, which was the plaintiff in the

federal district court and appellee in the Ninth Circuit

None of the parties are corporations.

There are no related cases.

iii

TABLE OF CONTENTS

QUESTION PRESENTED .................................................................................... ii

LIST OF PARTIES ............................................................................................... iii

TABLE OF CONTENTS ...................................................................................... iv

APPENDICES ......................................................................................................... v

TABLE OF AUTHORITIES ................................................................................ vi

PETITION ............................................................................................................... 1

I.

OPINION BELOW ......................................................................................... 2

II. JURISDICTION ............................................................................................. 2

III. CONSTITUTIONAL PROVISIONS INVOLVED ..................................... 2

IV. STATEMENT OF THE CASE AND PRIOR PROCEEDINGS ................ 2

V.

FACTUAL BACKGROUND ......................................................................... 4

VI. REASONS FOR GRANTING THE PETITION ......................................... 7

A. THE DECISION BELOW PERMITS RESIDENCE-WIDE DIGITAL SEARCHES

WITHOUT A SPECIFIC FACTUAL NEXUS AND REFLECTS A DIVERGENCE AMONG

COURTS.................................................................................................................. 7

B. THE DECISION BELOW PERMITS GENERAL DIGITAL WARRANTS AND

REFLECTS A DIVERGENCE REGARDING THE PARTICULARITY REQUIREMENT. ...... 12

C. THE QUESTION PRESENTED IS EXCEPTIONALLY IMPORTANT AND RECURS

WITH INCREASING FREQUENCY. .......................................................................... 15

D. THIS CASE IS AN EXCELLENT VEHICLE FOR RESOLVING THE QUESTION

PRESENTED. ......................................................................................................... 17

VII. CONCLUSION ............................................................................................. 18

iv

APPENDICES

Appendix A: United States v. Boudreau, 154 F.4th 1132 (9th Cir. 2025)

Appendix B: Order Re: Petition for Panel Rehearing and Rehearing En Banc

Appendix C: United States v. Boudreau, CR 22-46-M-DWM, Order Re: Denial of

Motion to Suppress

Appendix D: Residential Search Warrant and Affidavit

v

TABLE OF AUTHORITIES

TABLE OF CASES

Page No.

Armendariz v. City of Colorado Springs

169 F.4th 1036 (10th Cir. 2023) ................................................................... 10

Carpenter v. United States

138 S. Ct. 2206 (2018) ................................................................................. 13

Dougherty v. City of Covina

654 F.3d 892 (9th Cir. 2011) ...................................................................... 8, 9

Groh v. Ramirez

540 U.S. 551 (2004) ..................................................................................... 12

Illinois v. Gates

462 U.S. 213 (1983) ....................................................................................... 8

Marron v. United States

275 U.S. 192 (1927) ..................................................................................... 12

Riley v. California

573 U.S. 373 (2014) ......................................................................... 13, 15, 16

Silverman v. United States

365 U.S. 505 (1961) ....................................................................................... 7

United States v. Boudreau

154 F.4th 1132 (9th Cir. 2025) ....................................................... 2, 4, 5, 6, 7

United States v. Brown

828 F.3d 375 (6th Cir. 2016) .......................................................................... 9

United States v. Colbert

605 F.3d 573 (8th Cir. 2010) .................................................................. 10, 11

United States v. Falso

544 F.3d 110 (2d Cir. 2008) ......................................................................... 10

vi

United States v. Gourde

440 F.3d 1065 (9th Cir. 2006) (en banc) ........................................................ 8

United States v. Griffith

867 F.3d 1265 (D.C. Cir. 2017)...................................................................... 9

United States v. Hodge

246 F.3d 301 (3d Cir. 2001) ......................................................................... 11

United States v. Rosa

626 F.3d 56 (2d Cir. 2010) ........................................................................... 14

United States v. Triplett

684 F.3d 500 (5th Cir. 2012) ........................................................................ 14

vii

STATUTES AND RULES

Page No.

United States Constitution

U.S. Const. amend. IV. ....................................................................................... 2, 12

United States Code

28 U.S.C. § 1254(1) .................................................................................................. 2

18 U.S.C. § 2252A(a)(5)(B). .................................................................................... 3

18 U.S.C. § 2422(b) .................................................................................................. 3

viii

No. ______

__________________________________________________________________

IN THE

SUPREME COURT OF THE UNITED STATES

__________________________________________________________________

OCTOBER TERM 2025

__________________________________________________________________

CHRISTOPHER TODD BOUDREAU,

Petitioner,

v.

UNITED STATES OF AMERICA,

Respondent.

__________________________________________________________________

PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

__________________________________________________________________

Petitioner, Christopher Todd Boudreau (“Mr. Boudreau”) petitions for a writ

of certiorari to review the judgment of the United States Court of Appeals for the

Ninth Circuit.

This case presents the question:

Whether the Fourth Amendment permits a warrant to authorize a search

of a residence and the seizure of all electronic devices within it based

on generalized assumptions about digital evidence, where the

government has already obtained the device used in the alleged offense

and identifies no case-specific facts linking additional devices to the

home.

1

The Ninth Circuit’s published opinion conflicts with its own precedent and

reflects a divergence among the courts of appeals concerning the Fourth

Amendment’s nexus and particularity requirements in digital search cases.

I. OPINION BELOW

The opinion of the United States Court of Appeals for the Ninth Circuit

affirming the district court’s judgment is reported at United States v. Boudreau,

154 F.4th 1132 (9th Cir. 2025). Appendix A.

II. JURISDICTION

The court of appeals published its opinion affirming the district court’s

judgment on September 16, 2025. Appendix A. The court of appeals denied Mr.

Boudreau’s petition for rehearing and rehearing en banc on January 20, 2026.

Appendix B. This Court’s jurisdiction is invoked under 28 U.S.C. § 1254(1).

III. CONSTITUTIONAL PROVISIONS INVOLVED

U.S. Const., amend. IV

The right of the people to be secure in their persons, houses, papers, and

effects, against unreasonable searches and seizures, shall not be

violated, and no warrants shall issue, but upon probable cause,

supported by oath or affirmation, and particularly describing the place

to be searched, and the persons or things to be seized.

IV. STATEMENT OF THE CASE AND PRIOR PROCEEDINGS

Mr. Boudreau was indicted on October 6, 2022 in the United States District

Court for the District of Montana with attempted coercion and enticement of a

2

minor, in violation of 18 U.S.C. § 2422(b), and possession of child pornography, in

violation of 18 U.S.C. § 2252A(a)(5)(B). United States v. Christopher Todd

Boudreau, CR 22-46-M-DWM. Mr. Boudreau was arrested on July 28, 2022. He

was arraigned on October 27, 2022, and detained pending trial.

Before trial, Mr. Boudreau moved to suppress evidence seized from his

residence pursuant to a search warrant, arguing that the warrant violated the Fourth

Amendment because the affidavit failed to establish a sufficient nexus between the

alleged offense and his residence or any electronic device within it, and because

the warrant’s breadth rendered it unconstitutional. The warrant challenged here

authorized the search of Mr. Boudreau’s residence and the seizure of all electronic

devices within it. The district court denied the motion to suppress, concluding that

the affidavit established probable cause to search the residence and its electronic

devices. Order attached as Appendix C.

Following a jury trial, Mr. Boudreau was convicted on both counts. On

December 8, 2023, he was sentenced to concurrent terms of 154 months

imprisonment, followed by ten years supervised release.

Mr. Boudreau appealed to the United States Court of Appeals for the Ninth

Circuit on December 11, 2023. United States v. Christopher Todd Boudreau, CA

23-4092.

3

Mr. Boudreau’s case was argued and submitted on April 2, 2025. Mr.

Boudreau challenged, among other things, the denial of his motion to suppress.

The court of appeals issued its opinion affirming the district court on

September 16, 2025. The United States Court of Appeals for the Ninth Circuit

held that under the totality of the circumstances, the warrant was supported by

probable cause to search Mr. Boudreau’s residence for evidence of both enticement

and child pornography. The court upheld the warrant and affirmed the admission

of the evidence seized.

Mr. Boudreau filed a petition for rehearing and rehearing en banc on

December 23, 2025.

On January 20, 2026, the court of appeals denied Mr. Boudreau’s petition

for rehearing and rehearing en banc.

This petition follows.

V. FACTUAL BACKGROUND

In July 2022, law enforcement officers in Montana conducted a reverse sting

investigation using a fictitious online persona named “Mia,” who was represented

as a 12-year-old girl. Mr. Boudreau first communicated with “Mia” through a

social-media platform and then continued communicating with her by text message

over the course of several days. Boudreau, 154 F.4th at 1136.

4

During those communications, Mr. Boudreau expressed sexual interest in

“Mia” and arranged to meet her in person. Approximately eight days after

initiating contact, Mr. Boudreau traveled from his home in Anaconda, Montana, to

Missoula, Montana, intending to meet “Mia.” He was arrested upon arrival. Id. at

1136.

The communications underlying the investigation occurred through mobile

messaging platforms. The government did not identify any IP address, home

internet activity, or other information linking those communications to a computer

or electronic device located within Mr. Boudreau’s residence.

Following Mr. Boudreau’s arrest, Detective Wafstet applied for a warrant to

search Mr. Boudreau’s residence. The affidavit described Mr. Boudreau’s

communications with “Mia” and his expressed sexual interest in minors. Detective

Wafstet recounted that Mr. Boudreau admitted that he watched pornography in the

past and had a computer at his residence. Id. at 1136. The affidavit did not

identify any device located in the residence that was used in the alleged offense,

nor did it provide facts linking any device in the home to that offense. Warrant and

Affidavit, attached as Appendix D.

Instead, the affidavit relied on the affiant’s training and experience.

Detective Wafstet stated that individuals who engage in offenses involving minors

commonly use computers and electronic devices to communicate and to store

5

digital evidence, and that such individuals often maintain collections of sexually

explicit material in digital form. Based on those general assertions, the affidavit

concluded that because of how Mr. Boudreau communicated with “Mia,” he

“likely has a sexualized interest in children and depictions of children” and “that

evidence of child pornography and additional child enticement” was likely to be

found at Mr. Boudreau’s residence. Boudreau, 154 F.4th at 1137.

A state judge issued a warrant authorizing a search of Mr. Boudreau’s

residence for evidence of both enticement of a minor and possession of child

pornography. The warrant authorized the seizure of all electronic devices capable

of storing or transmitting digital data, as well as visual depictions of minors,

without limitation as to device, user, or data type. Id.

Law enforcement officers executed the warrant at Mr. Boudreau’s residence

and seized numerous electronic storage devices, including thumb drives; external

hard drives; computer towers; and digital media. After obtaining a second warrant

to search the data, officers discovered images and videos constituting child

pornography. Id. at 1137. His conviction on Count 2 was based entirely on

evidence obtained from the seizure and subsequent search.

//

//

//

6

VI. REASONS FOR GRANTING THE PETITION

A. The Decision Below Permits Residence-Wide Digital Searches Without a

Specific Factual Nexus and Reflects a Divergence Among Courts.

As a preliminary matter, the July 2022 warrant at issue authorized law

enforcement to invade Mr. Boudreau’s home, which stands at “the very core” of

the Fourth Amendment’s protections, Silverman v. United States, 365 U.S. 505,

511 (1961), and to seize all “electronic device[s] capable of receiving and

transmitting data or storing electronic data” and any “[v]isual depictions” of

minors “in a state of undress [or] engaging in sexual activity.” Boudreau, 154

F.4th at 1136.

The decision below does not rest on any device-specific or location-specific

facts. Instead, it permits a search of a residence and all electronic devices within it

based on three generalized propositions: that Mr. Boudreau used a digital

application to communicate, that such applications are accessible on computers and

smartphones, and that individuals expressing sexual interest in minors are likely to

possess digital evidence. Based on these facts and the officer’s training and

experience, the panel concluded that there was a fair probability that evidence

would be found at Mr. Boudreau’s residence.

But law enforcement had already identified and secured the specific device

used in the alleged communications, the cell phone recovered from Mr. Boudreau’s

vehicle during his arrest, before seeking authority to search the residence. See

7

App. D (search warrant and affidavit). The affidavit nevertheless identified no

facts suggesting that any additional device existed, was used in the offense, or

would be found in the home. Instead, the affidavit relied on generalized assertions

that electronic devices are commonly used to store and access digital data and that

such data may be transferred across devices. That reasoning does not establish a

nexus between any particular device and the alleged offense, nor does it establish a

connection between any such device and the residence.

The Ninth Circuit’s reasoning does not establish a “fair probability that

evidence of a crime will be found in a particular place.” Illinois v. Gates, 462 U.S.

213, 238 (1983). It substitutes technological capability and generalized inference

for the individualized factual nexus the Fourth Amendment requires. The Ninth

Circuit’s decision erodes the independent probable cause basis for finding a nexus

because the suspect used a smartphone application that could be accessible on

computers. This reasoning risks transforming the nexus requirement from a factspecific inquiry into a generalized inference that applies in virtually every case

involving digital communication.

Even under the Ninth Circuit’s own precedent, the warrant here cannot be

sustained. In Gourde, the court upheld a warrant based on specific facts linking

the defendant’s conduct to a computer likely located in the home. United States v.

Gourde, 440 F.3d 1065, 1071 (9th Cir. 2006). By contrast, in Dougherty, the court

8

rejected a warrant where the connection between the alleged offense and the place

to be searched rested on attenuated inference. Dougherty v. City of Covina, 654

F.3d 892, 898-99 (9th Cir. 2011). This case presents an even weaker nexus than

Dougherty: law enforcement had already identified and secured the device used in

the alleged communications, yet the affidavit supplied no facts linking any

additional device in the home to the offense. The decision below nevertheless

upheld a residence-wide search based solely on generalized assumptions about

digital technology.

Courts of appeals have taken materially different approaches to this

question. Some require case-specific facts linking the alleged offense to the

residence and the devices to be searched. See, e.g., United States v. Griffith, 867

F.3d 1265, 1268 (D.C. Cir. 2017) (holding that probable cause to search a

residence for cell phones cannot rest on the generalized assumption that individuals

possess such devices, absent facts linking such device containing incriminating

information to the residence); United States v. Brown, 828 F.3d 375, 384 (6th Cir.

2016) (holding that probable cause to search a residence cannot be inferred absent

facts directly connecting the residence to the alleged criminal activity, even where

the defendant is known to engage in that activity). Brown confirms that probable

cause requires a factual connection between the alleged offense and the place to be

searched; where, as here, the government identifies no device tied to the offense

9

and no facts linking any such device to the residence, that requirement is not met.

See also United States v. Falso, 544 F.3d 110, 121 (2d Cir. 2008) (holding that

probable cause was lacking where the affidavit alleged only that the defendant

appeared to have attempted to access a website, without facts establishing that

evidence would be found on a computer in the home). In Falso, the court rejected

probable cause where the affidavit relied on the mere appearance of attempted

access to illicit material, without any factual basis to believe such material would

be found on a computer in the home. Here, the court upheld a search based on the

similarly attenuated proposition that the applications used to communicate were

merely accessible on computers and smartphones, without any facts showing that a

computer was used in the alleged offense or that evidence would be found on any

device in the residence.

More recently, the Tenth Circuit has made clear that a warrant to search a

residence for electronic devices cannot rest on generalized assumptions about

digital evidence but must be supported by case-specific facts linking the suspected

offense to devices likely located in the home. See Armendariz v. City of Colorado

Springs, 169 F.4th 1036, 1054-55 (10th Cir. 2023). The decision below permits

precisely the type of inference these courts have cautioned against.

Other courts permit warrants based largely on generalized assumptions about

offender behavior and the nature of digital evidence. See, e.g., United States v.

10

Colbert, 605 F.3d 573, 578-579 (8th Cir. 2010) (upholding probable cause to

search a residence based on the defendant’s conduct and the inference that

individuals with a sexual interest in minors are likely to possess child pornography

in their homes); United States v. Hodge, 246 F.3d 301, 306–07 (3d Cir. 2001)

(allowing probable cause to rest on common-sense inferences about where

evidence is likely to be kept, rather than specific facts linking the residence to the

offense). But see also Colbert, 605 F.3d at 580 (Bright, J., dissenting) (noting that

several courts have rejected the proposition that probable cause for child

enticement or molestation alone establishes probable cause to search a residence

for child pornography). These cases permit probable cause to rest on generalized

behavioral inferences rather than specific, case-based facts linking the alleged

offense to a particular device or location. The decision below reflects a permissive

approach that allows a search of a residence and the seizure of all electronic

devices within it based on technological capability and generalized behavioral

inference alone.

This divergence is especially consequential in the digital context. Because

electronic communication is ubiquitous and virtually all applications are useable

on phones and computers or other electronic devices found in the home, a rule that

permits nexus to be inferred from the mere use of digital applications effectively

11

allows residence-wide searches in nearly every case. The Fourth Amendment

requires more than that.

B. The Decision Below Permits General Digital Warrants and Reflects a

Divergence Regarding the Particularity Requirement.

This case also presents a closely related question concerning the Fourth

Amendment’s independent particularity requirement. The defect in nexus directly

produced a failure of particularity. The warrant here authorized the search of a

residence and all electronic devices within it without limitation by device type,

user, or connection to the alleged offense. Because the affidavit identified no

specific device or data source, the magistrate imposed no meaningful limits on

which devices could be seized, leaving those decisions to executing officers.

The Fourth Amendment requires more. Even where probable cause exists, a

warrant must “particularly describ[e] the place to be searched, and the persons or

things to be seized.” U.S. Const. amend. IV. That requirement ensures that the

magistrate, not the executing officer, defines the scope of the search. Groh v.

Ramirez, 540 U.S. 551, 557-558 (2004); Marron v. United States, 275 U.S. 192,

196 (1927).

This case illustrates the relationship between nexus and particularity. When

an affidavit fails to tie the alleged offense to any specific device or data source, the

magistrate lacks any principled basis to limit the scope of the seizure. The result is

12

not simply a lack of probable cause, but a warrant that leaves the definition of what

may be seized to the discretion of executing officers.

That defect is especially pronounced here because the government had

already seized the cell phone used in the alleged communications before seeking

the warrant to search the residence. The warrant thus did not target an identified

device tied to the offense but instead authorized the seizure of all electronic

devices without any factual basis to believe additional devices contained relevant

evidence.

Electronic devices contain vast quantities of personal information, and

authorizing the wholesale seizure of such devices exposes far more than traditional

physical searches. This Court has recognized that digital devices hold “a digital

record of nearly every aspect of [a person’s] life.” Riley v. California, 573 U.S.

373, 395 (2014). The absence of meaningful, magistrate-imposed limits at the

point of seizure therefore creates a heightened risk of general, exploratory

intrusions.

This Court has likewise recognized that modern digital data allows the

government to assemble “detailed, encyclopedic” records that provide an “intimate

window into a person’s life.” Carpenter v. United States, 138 S. Ct. 2206, 2216–

17 (2018). Because such data reveals “the privacies of life,” id. at 2217,

13

authorizing the seizure of all electronic devices without meaningful limits permits

sweeping intrusions far beyond those contemplated in traditional searches.

Courts have taken different approaches to how the Fourth Amendment’s

particularity requirement applies to the seizure of electronic devices. Some require

a concrete, case-specific link between the devices to be seized and the alleged

offense, while others permit broader seizures where such a connection can

reasonably be inferred from the facts. The decision below eliminates that limiting

principle altogether, permitting the government to seize every electronic device in

a residence without any factual basis tying those devices to criminal activity.

Courts of appeals diverge on how the particularity requirement applies in

this context. Some require meaningful, ex ante limits that tie the items to be seized

to the suspected criminal activity. See, e.g., United States v. Rosa, 626 F.3d 56,

62-63 (2d Cir. 2010) (finding a warrant for electronic media insufficiently

particular where it failed to link the items to be searched and seized to the

suspected criminal activity and authorized an uncircumscribed search, though

applying the good-faith exception). Other courts have upheld broader seizures

where the scope of the warrant is supported by case-specific facts linking the

devices to the alleged offense. See United States v. Triplett, 684 F.3d 500, 505

(5th Cir. 2012) (upholding seizure of electronic devices where the warrant was tied

to locating a missing person and supported by facts connecting those devices to the

14

investigation). The decision below extends beyond both approaches. These cases

do not address whether the Fourth Amendment permits the government to seize all

electronic devices in a residence without any factual basis tying those devices to

criminal activity.

Here, the warrant’s breadth was not the product of judicial tailoring but the

predictable consequence of an affidavit that failed to tie the alleged offense to any

specific device or data source. When a warrant contains no meaningful limits

grounded in case-specific facts, it ceases to be particularized and instead becomes

general by design.

The decision below removes that limiting principle. It permits deviceneutral warrants untethered to specific facts and bounded only by officer

discretion. In the context of modern digital storage, where devices contain “the

privacies of life,” Riley, 573 U.S. at 395, that rule risks converting warrants into

modern general warrants. The Fourth Amendment does not permit the government

to seize every device in a home first and define the scope of its search later. That

rule collapses the particularity requirement in the digital context, where nearly

every investigation involves electronic devices.

C.

The Question Presented Is Exceptionally Important and Recurs With

Increasing Frequency.

The question presented is exceptionally important and arises with increasing

frequency in modern criminal investigations. Digital communication is now

15

ubiquitous. Investigations involving social media, text messaging, and internetbased applications routinely lead to requests for search warrants targeting

electronic devices in a suspect’s home. If generalized assumptions about offender

behavior and the mere capability of digital applications to be accessed on

computers or other electronic devices suffice to establish probable cause, then

residence-wide searches of electronic devices will become the default rather than

the exception.

The consequences are substantial. Electronic devices contain vast quantities

of personal information, including communications, photographs, financial

records, and internet history. A warrant authorizing a search of all such devices in

a home exposes the entirety of a person’s digital life to government scrutiny.

This Court has recognized that digital searches raise heightened Fourth

Amendment concerns because of the volume and sensitivity of the information

involved. See Riley, 573 U.S. at 393–97. The decision below expands the

circumstances under which such searches and seizures may be authorized, without

requiring a concrete factual link to the place or devices searched and seized.

Absent this Court’s review, courts will continue to apply divergent standards

to these increasingly common warrants, and the protections of the Fourth

Amendment will erode in the digital age.

16

D. This Case Is an Excellent Vehicle for Resolving the Question Presented.

This case is an ideal vehicle for resolving the question presented. The

Fourth Amendment issue was squarely raised in Mr. Boudreau’s motion to

suppress and was fully litigated in the district court and on appeal. The court of

appeals addressed the issue directly and upheld the warrant based on its probablecause analysis. The court of appeals did not rely on the good-faith exception. Nor

did it rely on any alternative ground that would insulate the constitutional question

from review.

The case presents a clean legal question. The material facts are undisputed:

the affidavit did not identify any specific device, data source, or location linking

the alleged offense to the residence, and the warrant authorized seizure of all

electronic devices in the home. There are no alternative grounds supporting the

judgment, such as reliance on the good-faith exception, that would complicate this

Court’s review.

Finally, the issue is outcome-determinative. The evidence seized pursuant to

the warrant formed the basis for Mr. Boudreau’s conviction for possession of child

pornography. If the warrant violated the Fourth Amendment, suppression would

be required.

This case therefore presents a clear and appropriate vehicle for resolving an

important and recurring question of federal law.

17

VII. CONCLUSION

For the above reasons, the petition for a writ of certiorari should be granted.

RESPECTFULLY SUBMITTED April 20, 2026.

/s/ David A. Mattingley

David A. Mattingley

DISTEFANO & MATTINGLEY, PLLP

423 First Ave. East

Po Box 2341

Kalispell, MT 59903

(406) 300-2343

Email: david@nwmontanalaw.com

Counsel of Record for CHRISTOPHER

TODD BOUDREAU

18