United States v. Reingold

Corey Reingold (defendant), a 19-year-old man, downloaded and distributed hundreds of images of child pornography through a peer-to-peer file sharing service. Reingold also admitted to sexually molesting his prepubescent sister on three separate occasions, one of which occurred after Reingold turned 18. The federal government (plaintiff) charged Reingold with distributing child pornography, a federal crime carrying a minimum sentence of five years, or 60 months. Reingold pleaded guilty. Prior to sentencing, the federal government raised two sentence-enhancement factors: (1) that Reingold had a pattern of sexually abusing his prepubescent sister; and (2) that Reingold used a computer to distribute child pornography. The federal government recommended a sentence of 168 to 210 months in prison. Instead, the district court sentenced Reingold to 30 months in prison, holding that applying the mandatory minimum sentence to Reingold would be cruel and unusual punishment because Reingold was extremely immature and would benefit more from rehabilitation than a lengthy prison sentence. The district court also declined to apply either sentence-enhancement factor, holding that (1) the enhancement for sexually abusing minors only applied to adults and Reingold was either a minor or an immature 18-year-old when he molested his sister; and (2) enhancing Reingold’s sentence because he used a computer would be double counting. The federal government appealed, arguing that the district court erred by refusing to apply the mandatory minimum sentence.