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United States Fourth Circuit

US v. Dowell, 13-4576

In this case, defendant pleaded guilty to twelve counts of production of child pornography and one count of transportation of child pornography and was given a 960-month sentence. The judgment is affirmed, where: 1) the district court erred when it incorrectly applied an upward sentencing adjustment for a "vulnerable victim" pursuant to U.S.S.G. section 3A1.1(b)(1) based upon one of the victims' age-related cognitive development and psychological vulnerability, factors that already were incorporated into an upward adjustment for the young age of the victims pursuant to sections 2G2.1(b)(1) and 2G2.2(b)(2); but 2) the error is harmless.

Appellate Information

  • Decided 11/13/2014
  • Published 11/13/2014


  • Grimm


  • United States Fourth Circuit


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