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United States v. Levin

Citation: Not availableDocket: 20-1078P

Court: Court of Appeals for the First Circuit; September 14, 2021; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, a defendant was convicted for possession of child pornography under 18 U.S.C. § 2252A, based on evidence obtained through an FBI investigation utilizing a Network Investigative Technique. The investigation led to the discovery of multiple files on the defendant's electronic devices, indicative of child pornography. Initially, the district court suppressed the evidence due to a warrant violation; however, the evidence was later admitted based on the good faith exception to the exclusionary rule. The appellate court reviewed several points raised on appeal, including sufficiency of evidence, the procedure for juror questions, and jury instructions. The court found that circumstantial evidence was sufficient to establish knowledge of the files, and the procedure for juror questions had not been objected to, warranting a plain error review which found no substantial rights affected. Furthermore, the jury instruction on 'knowingly' aligned with the defense's request, leading to a waiver of any objection. Ultimately, the appellate court affirmed the conviction, upholding the jury's finding of guilt and the imposed sentence of 78 months in prison followed by supervised release.

Legal Issues Addressed

Good Faith Exception to the Exclusionary Rule

Application: Despite initial suppression of evidence due to an invalid search warrant, the evidence was admitted under the good faith exception, leading to a remand for further proceedings.

Reasoning: Suppression of evidence was deemed unwarranted under the good faith exception to the exclusionary rule, and the case was remanded for further proceedings.

Juror Questions Procedure

Application: Jurors were allowed to submit questions through the forewoman for judicial review, a procedure not objected to by the defense, therefore reviewed for plain error.

Reasoning: During Levin's trial, jurors were instructed to submit simple questions through the forewoman for the judge's review, with reminders to focus only on testimony.

Jury Instruction on 'Knowingly'

Application: The jury was instructed that possession must be voluntary and intentional, aligning with the defense's requested instruction, hence no waiver of objection.

Reasoning: The judge charged the jury with a definition of 'knowingly,' clarifying that possession must be voluntary and intentional.

Possession of Child Pornography under 18 U.S.C. § 2252A

Application: The defendant was convicted for possessing child pornography involving a minor under twelve, confirmed through forensic analysis of his electronic devices.

Reasoning: Alex Levin was convicted by a jury for possession of child pornography involving a minor under twelve, violating 18 U.S.C. § 2252A(a)(5)(B) and (b)(2).

Sufficiency of Evidence Review

Application: The appellate court reviews challenges to the sufficiency of evidence de novo, favoring the prosecution, and upheld the conviction based on circumstantial evidence.

Reasoning: Regarding the sufficiency of evidence, challenges are reviewed de novo, favoring the prosecution.