United States Fourth Circuit

Defendant's sentence for knowingly possessing 300 to 600 images of child pornography, which included a distribution enhancement, is affirmed, where: 1) when an individual continually possesses child pornography over a period of ten years and admits that he distributed that pornography over the same period, it is reasonable for a district court to conclude that seven specific distributions during that period are closely connected with the ongoing offense of possession; and accordingly, 2) the district court in this case did not clearly err in finding that defendant's distribution activity was part of the same course of conduct as his offense of conviction.

Appellate Information

• Decided 04/23/2014
• Published 04/23/2014

Judges

• NIEMEYER

Court

• United States Fourth Circuit

Counsel