United States v. Hodge, No. 14-5256 (6th Cir. 2015)
Annotate this CaseHodge’s 15-year-old stepdaughter found a micro video recording device that had recorded her exiting the shower naked and wrapping a towel around herself. She also saw that Hodge had setting up a camera on one of her bedroom shelves. The girl called her mother, Hodge’s wife, who came home. Hodge told her he had destroyed the recording. Hodge’s wife called the police, who obtained a search warrant. A police forensic investigation of Hodge’s laptop computer uncovered multiple child pornography images. Hodge pleaded guilty to one count of receipt of child pornography. 18 U.S.C. 2252(a)(2). At sentencing, the district court declined to give him a two-point base-offense-level reduction under USSG 2G2.2(b)(1) that applies when “the defendant’s conduct was limited to the receipt or solicitation of material involving the sexual exploitation of a minor” with no intent “to traffic in, or distribute, such material.” The Sixth Circuit affirmed, reasoning that Hodge was also secretly recording videos of his stepdaughter naked, so his “conduct” was not “limited to” the receipt or solicitation of child pornography. The court rejected Hodge’s argument that his video voyeurism was not conduct that was “relevant” to his “offense conduct” under USSG 1B1.3.
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