United States v. Michael Stahl, 506 F. App'x 479

Stahl challenges the constitutionality of his statutory mandatory minimum sentence under 18 U.S.C. § 2252(b)(1) for distribution of child pornography.
Stahl pleaded guilty to an amended information charging distribution of child pornography; total offense level 27 with enhancements and a variance for acceptance of responsibility.
Stahl had zero criminal history points (Category I), yielding a guideline range of 70–87 months incarceration.
The mandatory minimum term was five years (60 months) with a maximum of twenty years; district court imposed the 60-month minimum.
Stahl objected to the presentence report (double counting and CHI overstated), argued § 2252(b)(1) unconstitutional as applied, and sought a sentence below the minimum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 2252(b)(1) conflict with Booker as applied to Stahl?	Stahl contends Booker allows court to negate the minimum.	Booker does not permit invalidation of mandatory minimums; enhancements and discretion remain constrained by statute.	Booker's framework cannot negate the minimum; §2252(b)(1) constitutional as applied.
Does the mandatory minimum violate separation of powers?	Mandatory minimum usurps judicial discretion and core sentencing function.	Congress may fix sentence; judicial discretion is still guided by statutory limits and §3553(a).	Courts have rejected separation-of-powers challenges to mandatory minimums.

United States v. Hughes, 632 F.3d 956 (6th Cir. 2011) (reviews de novo constitutional challenges to sentences)
United States v. Franklin, 499 F.3d 578 (6th Cir. 2007) (Booker does not nullify mandatory minimums)
United States v. Cecil, 615 F.3d 678 (6th Cir. 2010) (section 3553(a) does not authorize below-minimum sentencing)
United States v. Fink, 502 F.3d 585 (6th Cir. 2007) (recognizes distinction between distribution and possession offenses)
Mistretta v. United States, 488 U.S. 361 (1989) (upholds broad congressional sentencing power)