Case Explained: United States v. Meier

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-07-28 Docket: 1:23-CR-00419-RMR-1) The tenth circuit affirmed Christopher Meier’s conviction and 420-month sentence for conspiracy to distribute and distribution of child pornography. The court held that the district court did not commit clear or obvious error in applying the Production Cross Reference under U.S.S.G. § 2G2.2(c)(1) to calculate Meier’s offense level under § 2G2.1 (production) rather than § 2G2.2 (distribution). Meier, who raised the claim for the first time on appeal, failed to satisfy the second prong of the plain-error standard because the record did not support factual findings that he distributed child pornography to a minor intended to entice that minor into sexual activity. Specifically, the court found that neither the Presentence Investigation Report nor the government’s briefing contained definitive findings regarding the age or specific conduct of any “bait-girl” videos Meier allegedly used to entice victims. Consequently, the district court was not required to apply the seven-level enhancement under § 2G2.2(b)(3)(E), which would have resulted in a lower Guidelines range and prevented the application of the Production Cross Reference. The judgment and sentence are affirmed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.