Court Affirms 300-Month Prison Sentence for Child Pornography Offender

The United States Attorney’s Office for the Middle District of Pennsylvania announced that the United States Court of Appeals for the Third Circuit last week affirmed the prison sentence of Michael Coates, age 28. Coates, a former Bloomsburg, Pennsylvania resident, was previously sentenced by United States District Court Judge John E. Jones, III, to serve 300 months in prison for the production of child pornography.

According to United States Attorney Peter J. Smith, Coates pleaded guilty in May 2010. Coates admitted that he produced child pornography involving a child under the age of 5.

The charge against Coates resulted from an investigation by agents of the Federal Bureau of Investigation and the Bloomsburg Police Department. A federal grand jury indicted Coates in September 2008. Coates was sentenced by Judge Jones on May 27, 2011.

In appealing his sentence, Coates claimed that the district court failed to suppress evidence obtained from his cell phone, which he had voluntarily turned over to the Bloomsburg Police Department. He also claimed the district court failed to meaningfully consider relevant sentencing factors and did not adequately articulate its reasons for imposing the 300-month prison sentence. In rejecting those claims, the Third Circuit noted that there is no subjective expectation of privacy in an object voluntarily turned over to a third party and that Judge Jones adequately addressed the relevant sentencing factors such as the impact of Coates crime on the victim, the need for just punishment, the interest of public safety, as well as certain mitigating factors.

The case and appeal was handled by Assistant United States Attorney William Simmers.