Among other rulings on other issues, the Court reversed the defendant's conviction for bankruptcy fraud, holding that the income from his second religious temple, opened after the first temple filed a petition for bankruptcy and providing the same services as the first temple, did not constitute post-petition property of the first temple's estate since the temples otherwise operated as two separate entities and the government did not try to pierce the corporate veil.
The Court affirmed the district court's order sentencing the defendant to consecutive terms of imprisonment for violating his supervised release. Even though the district court had initially imposed concurrent terms of imprisonment and supervised release, the Guidelines allow a sentencing court to impose consecutive or concurrent sentences following the revocation of supervised release.
The Court affirmed the defendant's sentence. The district court did not err by holding that the Guidelines recommend consecutive maximum sentences for each count of conviction where the Guidelines range (life imprisonment) exceeds the statutory maximum for each count.
The Court held that officers’ warrantless two-day seizure of the defendant’s cell phone, based on evidence the defendant had sexually exploited a minor, was not permissible under Terry but was justified by probable cause and exigent circumstances. The Court also held that the sentencing court did not engage in double-counting by enhancing the defendant’s offense level for conduct involving a visual depiction of sexual acts and engaging in a pattern of prohibited sexual activities.
The Court affirmed the defendant’s sentence for child pornography after his offense level was enhanced based on his distribution of child pornography while he was in Jamaica. The Court held that a sentencing court may properly consider extraterritorial conduct if it is otherwise relevant conduct under the Guidelines.
