United States v. Sprigg, No. 10-14919 (11th Cir. 2012)
Annotate this CaseDefendant pled guilty to one count of receipt of child pornography and the district court applied a five-level enhancement for distribution of illicit images for the receipt, or expectation of receipt, of a non-pecuniary thing of value. On appeal, defendant argued that no evidence supported the application of the enhancement. Although the court found that the evidence that defendant distributed illicit images, there was insufficient evidence to support the other elements of the enhancement. Accordingly, the court vacated the sentence and remanded.
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