United States v. Kaufmann, No. 18-2742 (7th Cir. 2019)
Annotate this CaseKaufmann arranged to care for an elderly man in exchange for room and board. The arrangement ended when police arrested Kaufmann for stealing from the man. Packing Kaufmann’s belongings, the family discovered child pornography. A grand jury indicted Kaufmann for receiving and possessing materials involving sexual exploitation of a minor, 18 U.S.C. 2252(a)(2) and (a)(4). Kaufmann pled guilty. The mandatory minimum sentence for these convictions is enhanced to 15 years if the defendant has a prior conviction “under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward, or the production, possession, receipt, mailing, sale, distribution, shipment, or transportation of child pornography." The district court concluded that this enhancement applies because Kaufmann has prior Indiana convictions for possession of child pornography. The Seventh Circuit affirmed, rejecting Kaufmann’s argument that his convictions did not support the enhancement because the Indiana statute criminalized conduct broader than the federal version of possession of child pornography. The Seventh Circuit has held that a 2252(b) enhancement does not require the state statute of conviction to be the same as or narrower than the analogous federal law; the words “relating to” in section 2252(b) expand the range of enhancement-triggering convictions. Kaufmann’s Indiana convictions are ones “relating to … possession … of child pornography.”
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