United States v. Christopher Golden, No. 21-2684 (8th Cir. 2022)
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After a bench trial, the district court convicted Defendant on one count each of receipt and possession of child pornography under 18 U.S.C. Section 2252A(a)(2)(A) and (5)(B) and sentenced him to 97 months imprisonment. Defendant challenges the sufficiency of the evidence to support his convictions and the district court’s application of the sentencing guidelines.
The Eighth Circuit affirmed. According to Defendant, a rational jury could not have found that the evidence proved beyond a reasonable doubt that he knowingly received or possessed the child pornography found on his devices. The court explained that first, the thumbnails in Exhibits 1 to 4 support the district court’s finding that Defendant knowingly received and possessed those images or their originals. The examiner testified that a thumbnail indicates that the original of that image was in the phone’s gallery application at some point. Second, circumstantial evidence surrounding Exhibits 5, 6, and 8 to 13 supports the district court’s finding that Defendant knowingly possessed and received at least one of the images in these exhibits. Third, other evidence supports these inferences. Defendant’s devices contained thirteen child-pornography files, several suspected child-pornography files, and hundreds of other images of children—many erotic and some watermarked with child-pornography-related terms. Further, because the district court would have imposed the same sentence under Section 3553(a) factors as it did under the guidelines, any error in its application of the guidelines was harmless.
Court Description: [Gruender, Author, with Benton and Grasz, Circuit Judges] Criminal case - Criminal law and Sentencing. The evidence was sufficient to support defendant's convictions for receipt and possession of child pornography; even if the district court erred in imposing sentencing enhancements under Guidelines Sec. 2G2.2(b)(4)(B) for possession of materials depicting sexual exploitation of a toddler or under Guidelines Sec. 2G2.2(B)(7)(C) for possessing between 300 and 600 images, the error was harmless as the court stated it would impose the same 97-month sentence without the enhancements.
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