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Criminal Law: Child Pornography-Appeal Waiver-Substantive Reasonableness of Sentence

Staff Report//June 17, 2026//

Criminal Law: Child Pornography-Appeal Waiver-Substantive Reasonableness of Sentence

Staff Report//June 17, 2026//

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Defendant appealed the sentence imposed following his conviction for receipt of child pornography pursuant to a plea agreement containing an appeal waiver, challenging the substantive reasonableness of the sentence.

Although defendant’s sentencing challenge fell outside the scope of his appeal waiver, the court found the sentence reasonable where the district court properly considered the statutory sentencing factors.

Judgment is affirmed.

U.S. v. Guentert (MLW No. 84920/Case No. 25-2946 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Southern District of Iowa, Rose, J.

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