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Deason: Upholding Enticement and Obscene Transfer Convictions

By Tim Cone

In United States v. Deason, No. 17-12218 (July 17, 2020) (Ed Carnes, Branch, Tjoflat), the Court affirmed the defendant?s convictions for enticement of a minor and attempted transfer of obscene material.First, the Court upheld the denial of a motion to suppress statements made by the defendant in his home without receiving Mirandawarnings.  The Court concluded that the defendant was not ?in custody? based on the totality of the circumstances.Second, the Court found the evidence sufficient to convict on one of the obscene transfer counts.  The Court rejected the defendant?s argument that the government did not put all of the underlying videos as a whole into evidence, and instead admitted only screenshots from each video and had an agent testify about the contents...continue to full post

Full post as published by Defense Newsletter Blog on July 17, 2020 (boomark / email).