United States v. Ryan Moberg, 888 F.3d 966

In Nov. 2012 investigators using Shareaza on the Gnutella2 network downloaded incomplete video files from an IP flagged for sharing child pornography; three contained child pornography and one was from the "Jenny" series.
Law enforcement linked the IP to Moberg, obtained a warrant, and seized his computer on Apr. 4, 2013; a recorded interview that day captured Moberg admitting he used Shareaza after drinking, had searched for "Jenny" and "PTHC," and last viewed child pornography 4–5 months earlier.
Forensic examiners found six thumbnail images of child pornography (including two from the Jenny series) in the computer's thumbnail cache, evidence of prior storage of the original files; Shareaza and a PTHC search history were also present but the files downloaded in Nov. 2012 were not.
Moberg was tried and convicted of receipt of child pornography (Count 1, on or about Nov. 26, 2012) and possession of child pornography (Count 3, on or about Apr. 4, 2013); one other possession count was dismissed pretrial.
On appeal Moberg challenged (1) admission of his interview statements as improper prior-bad-act evidence under Fed. R. Evid. 404(b), and (2) sufficiency of the evidence supporting the possession conviction based on thumbnails.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of interview statements under Rule 404(b)	Moberg: statements were prior-bad-acts evidence offered to show propensity and therefore inadmissible	Gov't: statements were admissions or, at most, properly admissible under Rule 404(b) to show knowledge and intent	Court: Statements were probative of charged conduct/knowledge; admission not an abuse of discretion
Sufficiency of evidence for possession based on thumbnails	Moberg: no evidence he knew thumbnails existed or could access them, so no knowing possession	Gov't: thumbnails prove the originals were stored on the drive and support a finding of knowing possession	Court: Reasonable juror could find knowing possession; denial of acquittal affirmed

United States v. Stong, 773 F.3d 920 (8th Cir. 2014) (standard of review for evidentiary rulings)
United States v. Shores, 700 F.3d 366 (8th Cir. 2012) (distinguishing evidence of charged conduct from Rule 404(b) evidence)
United States v. Jones, 255 F.3d 916 (8th Cir. 2001) (four-part test for admissibility under Rule 404(b))
United States v. Worthey, 716 F.3d 1107 (8th Cir. 2013) (receipt and possession convictions require knowledge)
United States v. White, 806 F.3d 635 (8th Cir. 2015) (knowledge element discussed in context of child pornography cases)
United States v. Vega, 676 F.3d 708 (8th Cir. 2012) (standard for reviewing sufficiency of the evidence)
United States v. Huyck, 849 F.3d 432 (8th Cir. 2017) (evidence consistent with guilt need not exclude innocent explanations)
United States v. Griffith, 786 F.3d 1098 (8th Cir. 2015) (same on deference to jury findings)