United States v. Bruns, No. 09-3077 (D.C. Cir. 2011)
Annotate this CaseIn 2009, defendant pled guilty to a one-count information charging him with possession of child pornography in violation of 18 U.S.C. 2252A(a)(5)(B) and, in light of his 1999 Michigan state court proceeding where he pled guilty to distributing child pornography, the district court sentenced him to ten years imprisonment. At issue was whether defendant had such a "prior conviction" under the laws of the State of Michigan. The court concluded that if defendant had been convicted in state court of the conduct for which he was sentenced in federal court, his assignment under the Michigan Holmes Act, Mich. Comp. Laws 762.11, would have been treated as a "conviction" for determining his minimum sentence. It followed that even if Michigan law determined defendant's minimum federal sentence, he had a prior conviction under Michigan law relating to child pornography. Therefore, the court held that the district court properly imposed the ten year mandatory minimum sentence pursuant to section 2252A(b)(2).
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.