United States v. Robert Springstead, 520 F. App'x 168

Springstead was convicted after a two-day bench trial of multiple counts relating to distribution, receipt, and possession of child pornography, plus obscene visual representations of such abuse, and received a 204-month sentence.
On appeal, he challenged the district court’s admission of Special Agent Wolpert’s expert testimony about FTK-based forensic analysis.
He also challenged the admission of a two-page fictional story he authored at age fourteen about a six-year-old girl’s sexual encounters.
The government relied on Rule 702 for expert admissibility and Rule 404(b) with Rule 403 balancing for the prior-act letter/story, arguing relevance and probative value outweighed prejudice.
The district court admitted Wolpert as an expert and allowed discussion of FTK methodology; it also admitted the fourteen-year-old letter under Rule 404(b) for purposes other than character.
The court conducted harmless-error review for the 404(b) evidence and concluded any error was harmless given substantial other incriminating evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wolpert’s expert testimony was admissible under Rule 702.	Springstead argues Wolpert lacked requisite expertise to explain FTK.	Springstead contends the district court failed to ensure reliability and industry standards.	Admitting Wolpert’s testimony did not abuse discretion.
Whether the fourteen-year-old letter was admissible under Rule 404(b).	Letter shows propensity/character evidence prejudicial to Springstead.	Letter had independent relevance to knowledge/motive or plan under 404(b).	Any error was harmless.
Whether admission of 404(b) evidence violated Rule 403 balancing.	The letter’s prejudicial effect outweighed its probative value.	The evidence was highly probative and not substantially outweighing prejudice.	Harmless-error standard applied; no reversible error.
Whether the evidence at trial was sufficient to convict absent the 404(b) issue.	Claims of insufficient evidence if expert and letter are excluded.	Other substantial evidence supported convictions.	Sufficient evidence supported convictions.

United States v. Wilson, 484 F.3d 267 (4th Cir. 2007) (establishes abuse-of-discretion review for Rule 702 testimony)
Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (U.S. 1999) (flexible Daubert factors govern reliability of expert testimony)
Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (U.S. 1993) (reliability standard for expert testimony; non-exhaustive factors)
United States v. Johnson, 617 F.3d 286 (4th Cir. 2010) (forensic data extraction requires specialized knowledge beyond jurors)
United States v. Ganier, 468 F.3d 920 (6th Cir. 2006) (expert testimony about computers/forensic software within Rule 702)
United States v. Siegel, 536 F.3d 306 (4th Cir. 2008) (Rule 404(b) admissibility: relevance, necessity, reliability)
United States v. Queen, 132 F.3d 991 (4th Cir. 1997) (Rule 403 balancing: probative value vs. prejudice)
United States v. Lighty, 616 F.3d 321 (4th Cir. 2010) (harmless-error review for evidentiary errors under Rule 404(b))