United States v. Mateen, No. 12-4481 (6th Cir. 2014)
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Mateen pleaded guilty to possession of child pornography in violation of 18 U.S.C. 2252(a)(4)(B) after police discovered more than 600 images of child pornography on his computer. In 2006, Mateen had pleaded guilty to Gross Sexual Imposition in violation of Ohio Revised Code 2907.05. The state-court plea colloquy indicated that his victim was an eight-year-old girl. The district court imposed a ten-year statutory maximum term of imprisonment, concluding that a statutory enhancement (18 U.S.C. 2252(b)(2)) for recidivist sexual offenders did not apply to because Mateen’s prior conviction for Gross Sexual Imposition did not necessarily involve a minor or ward. The Sixth Circuit affirmed. The state statute under which he was convicted covers several possible offenses and the information concerning the viction was not essential to Mateen’s guilty plea.
The court issued a subsequent related opinion or order on April 9, 2014.
The court issued a subsequent related opinion or order on August 26, 2014.
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