Fourth Circuit - Sex Offenses

United States v. Miltier, 993 F.3d 267 (4th Cir. 2021). A defendant who used a peer-to-peer network to unintentionally distribute child pornography was not eligible for a 2-level reduction under §2G2.2(b)(1). The plain text of §2G2.2(b)(1) “forecloses eligibility where a defendant engages in distribution at all, irrespective of his mental state.”

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