The appellant challenges his conviction and sentence for various alleged offenses concerning child pornography. The "victim under the age of 12" enhancement does not bar application of the "vulnerable victim" enhancement when the victim is especially vulnerable, even as compared to most children under 12; there is no need to show that the particular vulnerabilities of the victims actually facilitated the commission of the crimes. The district court's judgment is affirmed. 5th U.S. Circuit Court of Appeals, No. 11-51277, 03-20-2013.
United States v. Jenkins
March 26, 2013