United States v. Paauwe, No. 19-2071 (6th Cir. 2020)
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Beginning when G.L. was 15 years old, Paauwe, an elementary school teacher, engaged in an online relationship with G.L., a special needs girl living several states away. Paauwe persuaded her to perform sexual acts and “punishment” on herself. During the two-year relationship, Paauwe amassed a collection of child pornography depicting G.L. and recorded an illicit video of a student and videos of himself masturbating at school. Paauwe eventually responded to an undercover officer’s sex-related social media post and “expressed disturbing views.” When officers interviewed him, Paauwe admitted that he struggled with sexual urges toward young girls and to viewing child pornography. A search of Paauwe’s phone revealed several images of child pornography, some depicting children as young as five engaged in sex acts with adults.
Paauwe pleaded guilty to coercion and enticement of a minor, 18 U.S.C. 2422(b). The PSR calculated a Guidelines range of 360 months to life imprisonment. Paauwe objected to the imposition of a five-level sentencing enhancement for “engag[ing] in a pattern of activity involving prohibited sexual conduct,” arguing that U.S.S.G. 4B1.5(b)(1) contemplates offenses against multiple minors. Application Note 4(B)(i) to 4B1.5(b)(1) indicates that the Guideline applies to a defendant who engages in prohibited sexual conduct with a single minor. Paauwe argued that an application note may not expand a Guideline’s scope. The Sixth Circuit affirmed his 420-month sentence, stating that Paauwe’s enhancement follows from the plain terms of the Guideline itself.
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