United States v. Hansen, No. 16-1894 (8th Cir. 2017)Annotate this Case
The Eighth Circuit affirmed defendant's sentence of 130 months in prison after he pleaded guilty to receipt of child pornography. The court held that the district court did not commit procedural error at sentencing by increasing defendant's guideline offense level by five levels under USSG 2G2.2(b)(3)(B) where the increase did not affect defendant's sentence and he did not suffer prejudice from any error in applying section 2G2.2(b)(3)(B). Therefore, the court need not address whether the district court's finding was adequately supported because any error in applying the five-level increase was harmless.