United States v. Travis Mayer, No. 22-1259 (8th Cir. 2023)
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Defendant was convicted of several child pornography-related offenses. He appealed the district court’s denial of his pretrial suppression motion, the application of a sentencing enhancement, and the grouping of his counts at sentencing.
The Eighth Circuit affirmed. The court explained that even if Defendant showed cause, he wasn’t prejudiced, which is required for good cause. The Government offered significant evidence at trial that supported Defendant’s conviction, including his incriminating admissions that he received and produced child pornography and explicit content recovered from his and the minor victim’s phones. While the motel room evidence was incriminating in the sense that it worked against Defendant, “[t]he desire to suppress” such evidence is “not by [itself] sufficient to establish good cause to justify relief from a waiver of a defense, objection, or request under Rule 12.” Thus, the district court did not abuse its discretion when it denied Defendant leave to make an untimely pretrial motion.
In calculating his sentence, Defendant says that the district court erred when it declined to group three counts together because those counts involved substantially the same harm. But the court explained that even if it grouped Defendant’s offenses the way he suggests, he would still receive a life sentence because his combined offense level would exceed 43, so any error was harmless.
Court Description: [Kobes, Author, with Loken and Melloy, Circuit Judges] Criminal case - Criminal law and Sentencing. The district court did not abuse its discretion in refusing to permit defendant to make an untimely pretrial motion to suppress; the district court did not err in finding, by a preponderance of the evidence, that the offense in question involved more than 600 images of child pornography; any error in refusing to group three counts together for sentencing purposes was harmless, as defendant would have received a life sentence even if the offenses had been grouped.
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