United States v. Jayden Debevec

Summary

The United States Court of Appeals for the Eighth Circuit affirmed Jayden M. Debevec’s convictions and sentence for attempted enticement of a minor using the internet under 18 U.S.C. § 2422(b). The court held that sufficient evidence supported the jury’s rejection of his entrapment defense and affirmed the denial of his motion for judgment of acquittal. It also upheld the admission of Amazon search-history evidence under Federal Rule of Evidence 404(b) and concluded that any error in admitting a WhatsApp conversation was harmless.

Holdings

1. The district court properly denied the motion for judgment of acquittal because sufficient evidence permitted a reasonable jury to find that Debevec was not induced by the government and, even if inducement were established, that he was predisposed to commit the charged offense.
2. The district court did not abuse its discretion by admitting Debevec's January 2023 Amazon searches for terms associated with sexually explicit material involving minors.
3. Even assuming the district court erred in admitting the WhatsApp conversation, any error was harmless and did not require reversal.

Questions Presented

1. Whether the evidence was sufficient to support the jury's rejection of Debevec's entrapment defense and therefore to support denial of his motion for judgment of acquittal.
2. Whether the district court abused its discretion by admitting Debevec's Amazon search history under Federal Rule of Evidence 404(b).
3. Whether admission of the WhatsApp conversation under Rule 404(b), even if erroneous, affected Debevec's substantial rights or required reversal.

Disposition

affirmed