United States v. Croghan, No. 18-3709 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed defendant's conviction and sentence for receipt or attempted receipt of child pornography. The court held that the district court did not plainly err in admitting images of a female minor relative defendant had uploaded under Federal Rule of Evidence 404(b); in striking an FBI agent's testimony regarding defendant's children; and by permitting the agent to explain why the FBI requested a no-knock warrant.
The court also held that the evidence was sufficient to support the jury's verdict convicting him of the knowing receipt of child pornography, as opposed to the lesser included offense of knowing access of child pornography. Finally, the court held that defendant's below-Guidelines sentence of 110 months' imprisonment was not substantively unreasonable where the district court did not abuse its discretion in sentencing defendant.
Court Description: [Smith, Author, with Melloy and Shepherd, Circuit Judges] Criminal case - Criminal law and sentencing. For the court's prior opinion on the government's appeal of a suppression order, see U.S. v. Horton, 863 F.3d. 1041 (8th Cir. 2017). The district court did not plainly err in admitting images of a female minor relative defendant had uploaded to PrimeJailBait.com, as the evidence was admissible under Rule 404(b) to establish motive, rebut claims of accident or mistake concerning the charged child pornography conduct and show identity as they were uploaded using the same user ID defendant used in accessing Playpen, a darknet server; the court did not plainly err in not striking an FBI agent's mention of defendant's children as it went to explain steps taken in the investigation; the court did not plainly err in permitting the agent to explain why the FBI requested a no-knock warrant in the case; evidence was sufficient to support the jury's verdict convicting defendant of knowing receipt of child pornography; defendant's below-guidelines sentence was not substantively unreasonable.
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.