United States v. Jack Knight
685 F. App'x 240
| 4th Cir. | 2017Background
- Jack Knight pleaded guilty to receiving child pornography in violation of 18 U.S.C. § 2252A(a)(2)(A).
- The district court adopted the presentence report (PSR) as the factual basis for the plea.
- PSR showed Knight’s laptop and CDs contained hundreds of images/videos; many files were in his downloads folder and some originated outside North Carolina or the U.S.
- Knight received a below-Guidelines sentence — an 87-month term reflecting a downward variance.
- Knight appealed, arguing (1) the record lacked a sufficient factual basis specifically for the "receiving" element, and (2) his sentence was substantively unreasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the record supplied a sufficient factual basis that Knight knowingly "received" child pornography | Knight: record shows only possession/downloads, not affirmative proof of "receiving" via interstate/foreign commerce | Government/District Court: files in downloads folder and origins outside NC/U.S. support that files were received/shipped via interstate or foreign commerce | Court: No plain error — PSR facts suffice to support the receipt element; plea upheld |
| Whether Knight's 87-month below-Guidelines sentence was substantively unreasonable | Knight: below-guidelines sentence still unreasonable under § 3553(a) totality analysis | Government: sentence is within/below Guidelines and presumptively reasonable; no procedural error alleged | Court: Affirmed — below-Guidelines sentence not rebutted as unreasonable |
Key Cases Cited
- United States v. Aplicano-Oyuela, 792 F.3d 416 (4th Cir. 2015) (plain-error standard for Rule 11 challenges when no plea withdrawal)
- United States v. Massenburg, 564 F.3d 337 (4th Cir. 2009) (elements of plain-error review)
- United States v. Ketchum, 550 F.3d 363 (4th Cir. 2008) (trial court must ensure factual basis for guilty plea)
- United States v. Morrow, 914 F.2d 608 (4th Cir. 1990) (trial court’s discretion in determining factual basis)
- Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review of sentencing)
- United States v. Gomez-Jimenez, 750 F.3d 370 (4th Cir. 2014) (substantive-reasonableness review under § 3553(a))
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-or-below-Guidelines sentences)