United States v. Knowlton

Summary

The Fifth Circuit held that computer files containing digital images and videos of child pornography constitute "material that contains child pornography" under 18 U.S.C. § 2252A(a)(2)(B), rejecting the argument that only tangible storage media qualify. The court also found no material variance between the indictment's "on or about" dates and the evidence of receipt, as a two-and-a-half-month variance was within acceptable bounds. The conviction for receipt of child pornography was affirmed.

Questions Presented

1. Whether computer files downloaded from a peer-to-peer network constitute 'material that contains child pornography' under 18 U.S.C. § 2252A(a)(2)(B).
2. Whether the dates of receipt proven at trial materially varied from the dates alleged in the indictment.