United States v. Pratt, No. 17-4489 (4th Cir. 2019)
Annotate this CaseDefendant appealed his conviction of eight counts related to sex trafficking and child pornography. The Fourth Circuit held that the district court should have suppressed the evidence from defendant's cellphone, and the error was not harmless because the remaining evidence did not satisfy the elements of the two child pornography counts. The court held, however, that the district court did not err in admitting the hearsay statements. Accordingly, the court vacated defendant's conviction as to the two child pornography counts and affirmed the other six counts, vacated defendant's sentence, and remanded to the district court.
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