Jacobson v. United States case brief

Jacobson v. United States case brief summary
503 U.S. 540 (1992)

CASE SYNOPSIS

Defendant filed a writ of certiorari to the United States Court of Appeals for the Eighth Circuit, to challenge the affirmance of his conviction under 18 U.S.C.S. § 2252(a)(2)(A) of the Child Protection Act of 1984, which criminalized the knowing receipt through the mails of a visual depiction that involved the use of a minor engaging in sexually explicit conduct.

CASE FACTS
Defendant was convicted of violating 18 U.S.C.S. § 2252(a)(2)(A) of the Child Protection Act of 1984, which criminalized the knowing receipt through the mails of a visual depiction that involved the use of a minor engaging in sexually explicit conduct. Defendant's entrapment defense had failed. On appeal, the court of appeals affirmed. Defendant challenged the affirmance.

DISCUSSION

• The Court reversed, holding that the government overstepped the line between setting a trap for the "unwary innocent" and the "unwary criminal." 
• The Court also held that, as a matter of law, the government failed to establish that defendant was independently predisposed to commit the crime for which he was arrested. 
• The Court determined that although defendant was predisposed to break the law, the government did not prove that this predisposition was independent and not the product of the attention that the government had directed towards defendant. 
• The Court noted that by making available illegal sexually explicit materials, the government not only excited defendant's interest in materials banned by law, but also exerted substantial pressure on defendant to obtain such materials.

CONCLUSION

The Court reversed the appellate court's affirmance of defendant's conviction under a provision of the Child Protection Act of 1984. The Court held that the government failed to establish that defendant was independently predisposed to commit the crime for which he was arrested.

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