United States v. Steinmetz, No. 17-3061 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's conviction for production of child pornography. The court held that the district court did not err by denying defendant's motion to suppress evidence seized from his home during a warrantless search because he consented to the search; the scope of the search did not exceed the scope of defendant's general consent; there was no err in admitting evidence of molestation of the victim and the pornographic anime defendant showed her because it established the context in which he took nude photos of her, as well as his grooming process; there was no error in admitting other child pornography found on defendant's computer; there was no error in admitting picture of defendant's ex-wife wearing a bondage costume identical to the one shown in the photos of the victim, as the picture tended to prove defendant took the photos of the victim; the district court did not abuse its discretion in limiting defendant's cross-examination of the victim concerning her depression and counseling as he failed to make any offer of proof to show how the questioning would have been relevant to the witness's credibility or bias.