United States v. Michael Wyatt
713 F. App'x 467
| 6th Cir. | 2017Background
- Wyatt (44) posted a sexually explicit Craigslist ad and exchanged messages with a TBI agent posing as a 14-year-old girl (“Lara”).
- Wyatt sent multiple nude images, solicited private/unclothed pictures, discussed meeting "safely," and acknowledged legal risk (e.g., "I'd go to prison till I died").
- Communications continued for several days despite repeated statements that "Lara" was 14; an in-person meeting was arranged.
- Wyatt arrived at the meeting with condoms and other items; he was arrested and gave a voluntary statement claiming he thought the profile was not real.
- He was indicted on attempted coercion/enticement of a minor (18 U.S.C. § 2422(b)) and attempted sexual exploitation of a child (18 U.S.C. § 2251), convicted by a jury, and sentenced to 180 months; he appealed the sufficiency of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: Did evidence support finding Wyatt believed the correspondent was a minor under § 2422(b) and § 2251? | The Government: messages, repeated age disclosures, explicit sexual requests, planning a meeting, and admissions of fear of getting caught support that a reasonable juror could find Wyatt believed Lara was under 18. | Wyatt: he did not believe Lara was a minor; thought she might be law enforcement, a prank, fantasy role-play, troll, or an adult client. | Affirmed: viewing evidence in the light most favorable to the prosecution, a rational juror could find Wyatt subjectively believed Lara was a minor and took substantial steps toward the offenses. |
| Attempt element: Did Wyatt take a substantial step beyond mere preparation? | Govt: arranging and traveling to a meeting with condoms and requested items constituted a substantial step toward consummation. | Wyatt: trip was to discover identity, not to commit the crime. | Affirmed: actions (communications, arrangements, travel with condoms) satisfied the substantial-step requirement for attempt. |
| Mens rea specificity: Must government prove subjective intent to commit crimes against a minor? | Govt: yes—showed by statements acknowledging illegality and continuing sexual solicitation after age was disclosed. | Wyatt: lacked mens rea because he doubted veracity of age claim. | Affirmed: jury reasonably inferred intent from repeated explicit solicitations and expressed concern about getting caught. |
| Entrapment (procedural/waiver issue) | Wyatt raised entrapment briefly on appeal. | Wyatt argued government induced him. | Waived: entrapment not preserved sufficiently in district court or developed on appeal, so claim waived. |
Key Cases Cited
- Lowe v. United States, 795 F.3d 519 (6th Cir. 2015) (standard for reviewing sufficiency of evidence on Rule 29 motion)
- Jackson v. Virginia, 443 U.S. 307 (1979) (benchmark for sufficiency of the evidence review)
- Roman v. United States, 795 F.3d 511 (6th Cir. 2015) (elements of § 2422(b) and attempt explained)
- Hart v. United States, 635 F.3d 850 (6th Cir. 2011) (defining elements of coercion/enticement statute)
- Evans v. United States, 699 F.3d 858 (6th Cir. 2012) (substantial-step analysis for criminal attempt)
- Lebowitz v. United States, 676 F.3d 1000 (11th Cir. 2012) (sufficiency where defendant continued solicitation after learning of minor’s age)
- Blanchard v. United States, 618 F.3d 562 (6th Cir. 2010) (deference to jury on credibility and inference drawing)