United States v. Valley, No. 13-2870 (7th Cir. 2014)
Annotate this CaseValley, age 29, posed on the Internet as a teenage boy and persuaded more than 50 underage girls to send him sexually explicit photos of themselves and convinced at least one of those girls to meet for sex. While executing a search warrant at his mother’s home, where he lived, agents had learned that Valley was using file-sharing software to distribute child pornography and the photos received from the girls. Valley made incriminating statements during the search and, after his indictment, the court denied his motion to suppress. Before trial, an examining psychologist concluded that Valley, although a grandiose liar, did not suffer any mental illness. Valley’s public defender was permitted to withdraw, and substitute counsel was appointed. He entered conditional guilty pleas to two counts of receiving child pornography, 18 U.S.C. 2252(a)(2), reserving his right to appeal. The Seventh Circuit affirmed, finding that Valley was not in custody when he made incriminating statements and that the explanation for the sentence was adequate. The judge acknowledged Valley’s struggles with mental illness and behavior disorders, yet expressed concern about the danger he presents to the community, describing Valley as a “conniving, manipulative, self-absorbed young man,” interested in only his own pursuits, from whom the community needs protection.
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