US v. Christie, 09-2908 - Criminal Law - U.S. Third Circuit
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US v. Christie, 09-2908

Conviction of defendant for child pornography and a 1,080-month sentence affirmed

US v. Christie, 09-2908, concerned a challenge to the district court's conviction of a defendant for various child pornography offenses and imposition of a sentence of 1,080-months' imprisonment, arising from a two-year investigation into the website of the North America Man-Girl Love Association (NAMGLA).

 

The court affirmed both the conviction and the sentence where: 1) the district court did not abuse its discretion or otherwise commit error, let alone plain error, in admitting an investigator's testimony concerning the confessions of other users of the website; 2) district court did not err in admitting into evidence two posts to the NAMGLA website; 3) the district court erred in admitting witness testimony regarding children's toys found in defendant's house, but the error was harmless given the truly overwhelming quantity of legitimate evidence against defendant; 3)  district court did not abuse its discretion in refusing to exclude defendant's composition notebooks under Rule 403; 4) district court did not abuse its discretion in questioning an investigator concerning the website; 5) defendant's claim of cumulative effect of the alleged evidentiary errors is rejected; 6) assuming that the Confidential Guidelines apply to the government's interactions with the informant, the alleged failures to abide by the Guidelines did not violate defendant's due process rights; 7) district court properly denied defendant's motion to suppress as he had no reasonable expectation of privacy in his IP address and cannot establish a Fourth Amendment violation; and 8) defendant's sentence was within the bounds of reasonableness.

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