United States v. Knowles, No. 14-3250 (8th Cir. 2016)
Annotate this CaseDefendant pleaded guilty to receiving and distributing child pornography, and was sentenced to a fifteen-year mandatory minimum term of imprisonment under 18 U.S.C. 2252(b)(1). The Supreme Court's decision in Lockhart v. United States held that the phrase “involving a minor or ward” in section 2252(b)(2) modifies only “abusive sexual conduct” and not “aggravated sexual abuse” or “sexual abuse.” Therefore, section 2252(b)(2) “applies to prior state convictions for ‘sexual abuse’ and ‘aggravated sexual abuse,’ whether or not the convictions involved a minor or ward.” In this case, the court concluded that a conviction for third-degree sexual assault under Nebraska Revised Statutes 28-320 categorically triggered a sentencing enhancement under section 2252(b)(1). Accordingly, the court affirmed the sentence.
Court Description: Wollman, Author, with Gruender, Circuit Judge, and Doty, District Judge] Criminal case - Sentencing. Applying the Supreme Court's recent decision in Lockhart v. United States, 136 S.Ct. 958 (Mar. 1, 2016), which held the phrase "involving a minor or ward" in 18 U.S.C. Sec. 2252(b)(2) modifies only "abusive sexual conduct" and not "aggravated sexual abuse" or "sexual abuse", the district court did not err in concluding a conviction for third-degree sexual assault under Nebraska Revised Statutes Section 28-320 triggered a sentencing enhancement under 18 U.S.C. Sec. 2252(b)(1).
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.