United States v. Lynn, 636 F.3d 1127

Lynn was convicted at trial of receipt/distribution of child pornography under §2252(a)(2) and possession under §2252(a)(4)(B), based on files found on his Limewire-downloaded laptop.
Evidence showed some depictions were produced in Georgia and Washington, with a portion of a video linked to Georgia and a copy mailed from Georgia to the United Kingdom; other video evidence linked to Washington.
Two witnesses (Crozier and Shepherd) testified that specific videos depicted minors and had moved through interstate channels; a portion of a video was shown in court.
Lynn argued the government failed to prove the interstate-commerce element for the specific digital files on his laptop and that receipt and possession were the same conduct, risking double jeopardy.
At sentencing, the district court applied a two-level vulnerable-victim adjustment under §3A1.1, and sentenced Lynn to 210 months for receipt and 120 months for possession, concurrent, with life on supervised release.
The panel vacated one conviction for double jeopardy and remanded for resentencing while upholding the §3A1.1 adjustment and the sufficiency of the interstate-commerce evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of interstate-commerce proof	Lynn	Lynn	Sufficient evidence to support interstate-commerce element
Double jeopardy for receipt and possession	Lynn	Lynn	Remand to vacate one conviction; avoid multiplicitous judgment
Vulnerable-victim adjustment validity	Lynn	Lynn	No reversible error; adjustment upheld

Barrett v. United States, 423 U.S. 212 (1976) (present-perfect interstate-commerce element indicates completed transfer)
Schales, 546 F.3d 965 (9th Cir. 2008) (possession vs receipt; media-specificity for double jeopardy)
Giberson, 527 F.3d 882 (9th Cir. 2008) (double jeopardy and possession/receipt considerations)
Brobst, 558 F.3d 982 (9th Cir. 2009) (multiplicity and conviction structure in child-pornography cases)
Davenport, 519 F.3d 940 (9th Cir. 2008) (plain-error standard for double jeopardy and substantial rights)
Lacy, 119 F.3d 742 (9th Cir. 1997) (production versus movement theories under §2252(a)(4)(B))
Guagliardo, 278 F.3d 868 (9th Cir. 2002) (production of depictions and interstate connection)
Hockings, 129 F.3d 1069 (9th Cir. 1997) (visual depictions include nontraditional formats)
Romm, 455 F.3d 990 (9th Cir. 2006) (visual depictions in Internet caches)
Wright, 625 F.3d 583 (9th Cir. 2010) (interstate-commerce proof related to internet transfers)