United States v. Rodney Dotson, Jr.
2013 U.S. App. LEXIS 7908
| 6th Cir. | 2013Background
- Dotson was charged with sexual exploitation of a minor under 18 U.S.C. §2251(a) and possession of child pornography under §2252(a)(4)(B).
- Government sought to redact portions of Dotson’s written statement; Dotson asked for full admission.
- District court admitted the redacted statement, ruling the redacted portions were irrelevant and inadmissible as hearsay.
- Dotson was convicted on both counts and sentenced to 22 years’ imprisonment with a 20-year supervised release term and various conditions.
- On appeal, Dotson argues (i) the district court abused its discretion in admitting the redacted statement and (ii) several supervised-release conditions were plainly erroneous; the court vacates and remands on the conditions while upholding admission of the redacted statement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of redacted statement under Rule 106 | Dotson contends redacted portions were relevant to context | Government argues redacted parts lacked relevance and would mislead | No abuse; redacted portions properly admitted or not required to be admitted |
| Plain-error review of supervised-release conditions | Dotson asserts lack of explicit rationale for conditions merits remand | Government contends conditions are appropriate given offense | Remand for reconsideration of several conditions; judgment vacated as to those conditions |
Key Cases Cited
- United States v. McAllister, 693 F.3d 572 (6th Cir. 2012) (rule of completeness limited; admission proper when relevant and clarifying)
- United States v. Dorrell, 758 F.2d 427 (9th Cir. 1985) (redaction allowed if nonessential to the charged conduct)
- Inman v. United States, 666 F.3d 1001 (6th Cir. 2012) (requires adequate articulation of rationale for supervised-release conditions on remand)
- United States v. Maxwell, 483 F. App’x 233 (6th Cir. 2012) (remand when district court fails to state rationale for restrictive conditions)
- United States v. Carter, 463 F.3d 526 (6th Cir. 2006) (harmless error if reasons for conditions are clear on record)