United States v. Greene, No. 19-3069 (7th Cir. 2020)
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Greene pleaded guilty to distributing child pornography, 18 U.S.C. 2252A(a)(1), 2252A(b)(1), and received a within‐guidelines 15-year prison sentence and a life term of supervised release. Greene argued that the sentence violated the parsimony provision of the sentencing statute, which requires that a sentence be “sufficient, but not greater than necessary.” He challenged the district court’s statement that, for him, at age 59, terms of 10 years and life would be “effectively the same” because his life after prison would be “short.”
The Seventh Circuit affirmed. The district court considered the guidelines and explained, with reference to section 3553(a)'s factors, why it believed that a life term of supervised release was necessary. Agents found approximately 2,850 images of child pornography on his laptop and a thumb drive; he had a prior conviction for child pornography and was subject to a statutory minimum term of 15 years in prison. While Greene admitted that he had a problem and that his actions had caused a lot of pain and injury, the court saw a need for deterrence and to protect the public.
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