United States v. Libbey-Tipton, No. 18-4067 (6th Cir. 2020)
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The FBI became aware of the “Playpen” child pornography website on the dark web, gained control of the website and ran it for 13 days, tracking the registered users. The “Revenger” account accessed 205 postings, labeled: “11 YO boys fucking,” “girls changing on beach,” and “preteen videos girls hardcore.” With a warrant, the FBI traced the Revenger account to Libbey-Tipton’s IP address and computers’ MAC addresses at his Cleveland residence. A warranted search was executed. All of the seized devices showed indicia of child pornography in “previews” and were from Libbey-Tipton’s bedroom, the basement, and the garage. The previews did not find any evidence of child pornography on devices that belonged to the other residents--his mother, his brother, his girlfriend, and his brother’s girlfriend. The MAC addresses of the seized devices corresponded to images viewed by the Revenger account.
Libbey-Tipton was indicted for accessing and possessing child pornography. The government was allowed to introduce evidence of Libbey-Tipton’s prior conviction of child molestation as evidence of his propensity to access and possess child pornography. Convicted, Libbey-Tipton was sentenced to 235 months in prison, 27 months below the advisory Guidelines range. The Sixth Circuit affirmed, rejecting Libbey-Tipton’s challenges to the admissibility of his prior conviction, the reasonableness of his sentence, and the effectiveness of trial counsel. The court also upheld the denial of his motion to suppress the search warrant that led to his identification as a Playpen user.
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