United States v. Sheldon

Under 18 U.S.C. § 2251(a) the Government does not need to prove a defendant’s knowledge concerning the interstate commerce travel of materials used in the production of child pornography.

After being convicted of sexual exploitation of a child and knowingly receiving child pornography, Kevin Michael Sheldon (“Sheldon”) received a prison sentence of 480 months. Sheldon appealed his verdict, arguing that the district court erred in its interpretation of 18 U.S.C. § 2251(a), the district court abused its discretion, and that the jury lacked sufficient evidence to convict him of sexual exploitation. Sheldon claimed that the language of 18 U.S.C. § 2251(a) required the Government to prove his knowledge with respect to the interstate travel of the materials used in the child pornography production. However, the three independent clauses of the statute do not require the Government to prove Sheldon’s knowledge of the interstate travel. The Government only needed to prove that the materials used in the child pornography production had in fact traveled in interstate commerce. This was sufficiently proved. Evidence admitted concerning Sheldon’s prior possession of child pornography conviction was not an abuse of the district court’s discretion and sexually explicit videos presented to the jury constituted sufficient evidence to convict Sheldon of sexual exploitation. Therefore, Sheldon’s verdict is affirmed due to the district court’s accurate interpretation of 18 U.S.C. § 2251(a), the district court not abusing its discretion, and the jury having sufficient evidence for a sexual exploitation conviction. AFFIRMED.