United States v. Kevin Sheldon

Defendant Kevin Michael Sheldon appeals the jury verdict finding him guilty of sexual exploitation of a child in violation of 18 U.S.C. § 2251 (a) and knowingly receiving child pornography in violation of 18 U.S.C. § 2252A(a)(2). He argues that the district court erred in its interpretation of § 2251(a) because the court did not require the Government to prove his knowledge of the interstate nature of his crime. Our court has never directly addressed whether § 2251(a) requires that the defendant have knowledge that the materials used to produce child pornography had traveled in interstate commerce. We hold that the statute contains no such requirement.

Defendant also contends that the district court abused its discretion at trial when the court admitted evidence of his prior conviction for possession of child pornography, and that his sexual exploitation of a child conviction must be set aside because the evidence was insufficient for a rational jury to find him guilty. Those arguments lack merit. We affirm.

I. Background

Defendant Sheldon lived with family members in Montana. In September 2011, Defendant was told to move out of the family home because he had…