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Criminal Law: Child Pornography-Sufficiency of Evidence-Sentencing Package Doctrine

Staff Report//June 17, 2026//

Criminal Law: Child Pornography-Sufficiency of Evidence-Sentencing Package Doctrine

Staff Report//June 17, 2026//

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Defendant appealed his conviction and sentence for sexual exploitation of a minor and child pornography, arguing that there was insufficient evidence to support his child pornography conviction and that his sentence was improper under the sentencing package doctrine.

Where the nature of the images entered into evidence upon defendant’s stipulation supported an inference that defendant captured the images to satisfy sexual desires, there was sufficient evidence to support the child pornography conviction, and thus there was no basis to vacate defendant’s conviction under the sentencing package doctrine.

Judgment is affirmed.

U.S. v. Dudko (MLW No. 84938/Case No. 25-2978 – 4 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Missouri, Harpool, J.

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