United States v. Chambers
642 F.3d 588
| 7th Cir. | 2011Background
- Chambers used AOL chatrooms to contact Kendal, a 14-year-old; the interaction spanned 14 months with sexually explicit chats, images, and plans.
- An undercover agent posed as 13-year-old Jen; Chambers engaged in explicit chats and sent pornographic material.
- An undercover agent posed as 13-year-old Kaitlyn; Chambers exchanged explicit language and imagery.
- Chambers admitted frequenting chatrooms and engaging with minors; he claimed no intent to meet, but the jury could disbelieve him.
- A warrant was executed in June 2007, leading to the seizure of Chambers' computer and interviews; charges included transporting child pornography and later enticement of a minor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for attempted enticement | Chambers lacked intent to meet Kendal and took no substantial step | No substantial step; no intent to meet; mere talk | Yes, substantial step and intent supported conviction |
| Admissibility of Rule 404(b) evidence | Evidence relevant for motive/intent; probative and properly limited | Evidence unfairly prejudicial; insufficient limiting instruction | Admissible; proper limiting instruction provided |
Key Cases Cited
- United States v. Gladish, 536 F.3d 646 (7th Cir. 2008) (establishes substantial step standard and grooming focus)
- United States v. Rovetuso, 768 F.2d 809 (7th Cir. 1985) (substantial step requires more than mere preparation)
- United States v. Berg, 640 F.3d 239 (7th Cir. 2011) (Grooming as a target of 2422(b); focus on intended effect on minor)
- United States v. Hensley, 574 F.3d 384 (7th Cir. 2009) (grooming and intent relevant to 2422(b))
- United States v. Sebolt, 460 F.3d 910 (7th Cir. 2006) (predecessor to 404(b) motive/intent reasoning)