US V. Spriggs

United States v. Spriggs, heard in the Eleventh Circuit Court of Appeals. Spriggs pleaded guilty to receiving child pornography and was given a five-level sentencing enhancement for distributing illicit images. The appeal challenged this enhancement, arguing a lack of evidence supporting the expectation of receiving something of value in return for the distribution. The court found that while Spriggs did distribute files, there was insufficient evidence to prove he did so with the expectation of receiving valuable consideration, like faster downloads or more illicit material. Ultimately, the Eleventh Circuit vacated the sentence and remanded the case for resentencing, disagreeing with the lower court and the Eighth Circuit's interpretation of file-sharing program operation.