US v. Cobler: Cobler sexually abused a four-year-old boy (at a time when he was "afflicted by a serious communicable disease"), which he documented on video and in pictures. He also admitted to downloading and sharing child pornography over a peer-to-peer network on the Internet. Cobler pleaded guilty to multiple child pornography offenses, including three production counts, and was sentenced to 120 years in prison.
The Fourth Circuit affirmed Cobler's sentence. He argued first that it violated the Eighth Amendment's ban on cruel and unusual punishment. The court reaffirmed its position that an "extensive proportionality" analysis is available only in cases of actual life terms in prison or de facto life terms. It then concluded, as the first step of that analysis, that Cobler's sentence was not "grossly disproportionate to his crimes." Calling his conduct "shocking and vile," the court concluded it was "at least as grave" as the cases in which the Supreme Court had upheld life sentences. The court also found Cobler's sentence to be reasonable, concluding that he had not rebutted the presumption of reasonableness for his within-the-Guidelines sentence.