Quick Hits - Adam Walsh Act, 3582 Appeals, Access Devices

These cases don’t require a lot of discussion, but folks ought to be aware of them:

• US v. Charboneau: In this Adam Walsh Act case the Fourth Circuit held that a diagnosis of “paraphilic disorder” is not required in order to commit someone under the Act as a sexually dangerous person.
• US v. Martin: In this pair of consolidated cases, the Fourth Circuit held that in denying a defendant a reduced sentence under 18 USC 3582, the district court must provide an explanation sufficient enough for the court of appeals to substantively review the decision (just like any other sentencing).
• US v. Carver: The issue in this case is whether the $500-per-device loss measurement in access device cases requires working access devices. The Fourth Circuit concluded that it does not, creating a circuit split with the Ninth Circuit.