United States v. Dean Doutt

THAPAR, Circuit Judge.

Dean Doutt pled guilty to receiving child pornography. The district court enhanced his sentence because it found that he had engaged in a "pattern of activity involving the sexual abuse or exploitation of a minor." U.S. Sentencing Guidelines Manual § 2G2.2(b)(5) (U.S. Sentencing Comm'n 2016). But the district court used the wrong legal standard when it applied this enhancement, so we vacate and remand for resentencing.

I

Dean Doutt thought he could secretly obtain child pornography online using a video-conferencing application. He was wrong. Turns out, the federal…