U.S. v. Fulford, No. 10-12916 (11th Cir.) (662 F.3d 1174) (November 14, 2011) (Judge Edward E. Carnes)
Here the Court vacated a five-level sentencing enhancement imposed pursuant to U.S.S.G. ยง 2G2.2(b)(3) for distribution of child pornography to a minor because the Government had failed to prove that the recipient was a minor.
In a rare narrowing of the scope of a child pornography enhancement under the Guidelines, ...
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