United States v. Snodgrass
635 F.3d 324
| 7th Cir. | 2011Background
- Snodgrass was convicted on one count of attempting to receive child pornography and two counts of possessing child pornography.
- The district court calculated Guideline ranges of 235–240 months for the first count and 120 months for the other counts, with statutory caps.
- He was sentenced to 360 months, ten years above the guidelines.
- Inspections and a controlled delivery occurred after postal inspectors used email to offer Daphne (age 10) videos; Snodgrass ordered three Daphne videos.
- During the search, Snodgrass waived Miranda rights in a laundry-room interview and made statements later challenged as involuntary.
- Bauer testified about Carlin’s hostility toward Snodgrass, which the district court excluded as hearsay; the jury heard the rest of the trial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Snodgrass's suppression motion properly denied? | Snodgrass argues custody and coercion rendered statements involuntary. | Snodgrass contends waiver was involuntary and statements should be suppressed. | Statements not in custody; voluntary waiver affirmed. |
| Should Bauer's hostile-relationship testimony have been admitted? | Relevance to motive and context; carlin’s conduct affected case. | Testimony was hearsay and not within Bauer's personal knowledge. | District court did not abuse discretion; exclusion upheld. |
| Is Snodgrass's sentence reasonable given the § 3553(a) factors? | Upward variance justified by egregious, lifelong abuse and extensive evidence. | Sentence excessive and unexplained. | Sentence affirmed as reasonable; district court provided substantial written analysis. |
Key Cases Cited
- United States v. Figueroa-Espana, 511 F.3d 696 (7th Cir.2007) (review standard for suppression decisions; custody and voluntariness)
- United States v. Budd, 549 F.3d 1140 (7th Cir.2008) (custody assessment factors for Miranda)
- United States v. Thompson, 496 F.3d 807 (7th Cir.2007) (custody determination in totality of circumstances)
- United States v. Barker, 467 F.3d 625 (7th Cir.2006) (factors for voluntariness and waiver)
- United States v. Carson, 582 F.3d 827 (7th Cir.2009) (voluntariness of Miranda waiver standards)
- Rita v. United States, 551 U.S. 338 (2007) (explanation requirements under 18 U.S.C. § 3553(a))
- Gall v. United States, 552 U.S. 38 (2007) (reasonableness of sentence and need for explanation)
- United States v. Huerta, 239 F.3d 865 (7th Cir.2001) (considerations of coercion and mental state in voluntariness)
- Dillon v. United States, 150 F.3d 754 (7th Cir.1998) (voluntariness standard framework for waivers)