United States v. Hyatt, No. 21-1212 (7th Cir. 2022)
Annotate this Case
Officers received a tip from Dropbox, a well-known cloud-storage host, that someone had uploaded child pornography. They tracked the IP address to Hyatt’s home, where he admitted that he had uploaded the files. Hyatt was charged with transporting, receiving, and possessing child pornography, 18 U.S.C. 2252(a)(1), 2252(a)(2), 2252(a)(4)(B). Hyatt entered a guilty plea, unaccompanied by any agreement, to the receiving offense. The PSR determined that he had a total offense level of 34, applying five enhancements. Hyatt had 22 criminal history points, leading to a guidelines range of 262-327 months’ imprisonment. Hyatt did not object to the calculations but argued that the court should disregard the enhancements for sadistic behavior, prepubescent children, using a computer, and 600 or more images, arguing that they apply to almost everyone charged with child-pornography offenses. He did not mention the two-level “knowing distribution” enhancement, U.S.S.G. 2G2.2(b)(3)(F), based on the fact that Hyatt “uploaded 65 files of child pornography on Dropbox.”
The Seventh Circuit vacated Hyatt’s 293-month sentence. Hyatt did not waive the right to challenge the enhancement on appeal and the error was prejudicial to him. The court noted the lack of evidence or findings that Hyatt took any steps to make the uploaded files available to others.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.