United States v. Christopher Eads, 2013 U.S. App. LEXIS 18737

Eads was charged with distributing and possessing child pornography and tampering with a witness, and chose to represent himself after a pretrial Faretta inquiry and standby counsel appointment.
Evidence included images and short video clips of child pornography found on Eads’s home computer, and recorded jailhouse calls to his wife attempting to recant her police statements.
Before trial, the government and defense stipulated to the content of the charged images to streamline presentation, while Eads disputed ownership and his knowledge of possession.
During trial, the court admitted photographs, video clips, and jailhouse calls over defense objections, and the jury was instructed on the admissibility and purpose of the evidence.
At sentencing, the court imposed 480 months’ imprisonment after balancing § 3553(a) factors, with an initial total guideline range effectively higher than the imposed term.
Eads moved for a new trial and appealed, challenging the self-representation ruling, evidentiary rulings, sufficiency of the evidence, and sentencing decisions, all of which the court rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse discretion by allowing self‑representation?	Eads contends waiver was not knowing and intelligent.	Court did thorough Faretta inquiry; waiver was knowing and voluntary.	No abuse; waiver was knowing and intelligent.
Was Rule 403 harmless error in admitting images/videos of child pornography?	Stipulation moots need to admit; evidence inflamed the jury.	Images aided proving possession/knowledge and were probative.	Harmless error; cumulative and overwhelming evidence supported conviction.
Was there sufficient evidence to convict on the witness tampering count?	Evidence from jailhouse calls inadequate to prove intent to influence testimony.	Conversations show attempts to manipulate and induce false testimony.	Evidence sufficient; reasonable jury could find guilt beyond reasonable doubt.
Did the district court abuse its discretion in denying a new trial based on newly discovered evidence?	New evidence could exonerate after trial.	Evidence offered was insufficient and improperly supported.	No abuse of discretion; denial affirmed.
Did the court adequately address § 3553(a) factors for sentencing the witness tampering count separately?	Needed explicit § 3553(a) discussion for tampering count.	Courts may discuss § 3553(a) factors comprehensively; not required for each offense.	District court gave meaningful consideration; sentence reasonable.

Faretta v. California, 422 U.S. 806 (U.S. 1975) (establishes right to self-representation and Faretta inquiry requirements)
United States v. Avery, 208 F.3d 597 (7th Cir. 2000) (factors for determining knowing and intelligent waiver of counsel)
United States v. Loughry, 660 F.3d 965 (7th Cir. 2011) (Rule 403 balancing requires substantial explanation beyond pro forma statements)
United States v. Miller, 688 F.3d 322 (7th Cir. 2012) (require careful analysis of prejudice in Rule 403 decisions)
United States v. McKibbins, 656 F.3d 707 (7th Cir. 2011) (prejudice vs. probative value in Rule 403 balancing)
Gall v. United States, 552 U.S. 38 (U.S. 2007) (reasonableness standard for sentencing decisions under 18 U.S.C. § 3553(a))
United States v. Wortman, 488 F.3d 752 (7th Cir. 2007) (standard for reviewing sufficiency of evidence; deference to jury verdicts)
United States v. LaShay, 417 F.3d 715 (7th Cir. 2005) (definition of corruptly persuading a witness)
United States v. Starks, 309 F.3d 1017 (7th Cir. 2002) (sufficiency of the evidence standard)