US v. Williams: Williams sexually exploited a friend’s minor daughter, after “practicing” by “using his pinhole cameras by covertly photographing children on the school bus he drove.” In total, investigators seized over 100,000 images of child pornography. After pleading guilty to one count of production of child pornography, Williams faced an advisory Guideline range of 210 to 262 months in prison. At sentencing, Williams argued for a variance down to the mandatory minimum of 180 months in prison, while the Government sought a sentence at the top of the range. The district court rejected both arguments and imposed a sentence of 327 months in prison, followed by a life-time term of supervised release.
On appeal, the court affirmed Williams’ sentence. It rejected Williams’ argument that the district court did not provide proper notice before departing from the Guideline range, as the sentence imposed was not a departure at all, but a variance based on applying the 3553(a) sentencing factors, for which such notice is not required. The court also held that the district court did not err by basing its sentence on the fact that the victim had developed emotional problems without providing Williams access to her medical records, noting that he did not request it. Finally, the court held that the sentence was sufficiently explained.