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Child Pornography Vacated

Patterson Belknap Webb & Tyler LLP

Circuit Vacates Child Pornography Sentence For Second Time, Citing District Court’s Failure to Follow Circuit’s Mandate

On June 19, 2018, in a split decision in United States v. Sawyer, No. 15-2276 (Jacobs, Pooler, Crawford) the Circuit issued a firm rebuke of a District Court judge who – per the Circuit’s mandate – reduced the defendant’s...more

Patterson Belknap Webb & Tyler LLP

Second Circuit Continues To Give A Close Look To Supervised Release Conditions

In a recent nonprecedential summary order, the Second Circuit (Winter, Lynch, Chin) vacated and remanded a sentence due to a condition of supervised release that prohibited the defendant from having unsupervised contact with...more

Patterson Belknap Webb & Tyler LLP

In 2-1 Decision, Second Circuit Vacates Child Pornography Sentence as Substantively Unreasonable

For the third time in the past year, the Second Circuit in United States v. Jenkins, No. 14-4295 (Kearse, Jacobs, Parker), has vacated as substantively unreasonable a sentence imposed under the sentencing guideline for child...more

Patterson Belknap Webb & Tyler LLP

Divided Court Withdraws Opinion Vacating 60-Year Child Pornography Sentence and Affirms the Sentence as Procedurally and...

In United States v. Brown, No. 13-1706, the Second Circuit (Pooler, Sack, and Droney), withdrew the Court’s June 14, 2016 opinion, vacating Nathan Brown’s sixty year prison sentence on three counts of production of child...more

Patterson Belknap Webb & Tyler LLP

In A Summary Order, Second Circuit Vacates 30-year Child Pornography Sentence on Substantive Reasonableness Grounds

In United States v. Sawyer, No. 15-2276, the Second Circuit (Jacobs, Pooler, Crawford) vacated and remanded for resentencing a case involving a conviction for possession of child pornography. The decision rested on a finding...more

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