The U.S. Court of Appeals for the Sixth Circuit affirmed Tuesday the conviction and 80-year prison sentence of Jarrod Sanford on multiple federal child exploitation charges, rejecting his challenges to evidence admission and the length of his sentence.
Sanford was convicted by a jury in the U.S. District Court for the Western District of Tennessee on three federal charges: production of child pornography in violation of 18 U.S.C. § 2251(a)&(e), possession of child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B), and committing a felony offense with a minor while being required to register as a sex offender in violation of 18 U.S.C. § 2260A. The district court sentenced him to 960 months of imprisonment.
In a decision filed Jan. 7, 2026, a three-judge panel consisting of Circuit Judges Alice Batchelder, John Bush, and Chad Readler unanimously affirmed the district court's judgment in its entirety. The opinion was designated as "not recommended for publication," indicating it will have limited precedential value.
On appeal, Sanford raised several arguments challenging both his conviction and sentence. He contended that the district court erred in admitting evidence that he had raped and sexually abused the child victim on occasions other than those specifically charged in the indictment. Such evidence, known as "other acts" evidence, is generally inadmissible unless it serves a specific permissible purpose under Federal Rule of Evidence 404(b).
Sanford also argued that the district court committed plain error in permitting certain testimony regarding the victim's out-of-court statements. This challenge appears to involve hearsay evidence, which is generally inadmissible unless it falls within an exception to the hearsay rule.
Regarding his sentence, Sanford contended that the 80-year prison term was both procedurally and substantively unreasonable. Procedural reasonableness challenges typically focus on whether the district court properly calculated the sentencing guidelines range and considered all relevant factors. Substantive reasonableness challenges argue that the sentence imposed is too harsh given the circumstances of the case and the defendant.
Sanford further argued that there was insufficient evidence to support his conviction for production of child pornography and for committing that offense while being required to register as a sex offender. Sufficiency of evidence challenges require appellate courts to determine whether a reasonable jury could have found the defendant guilty beyond a reasonable doubt based on the evidence presented at trial.
The Sixth Circuit rejected all of Sanford's arguments. While the court's reasoning is not detailed in the available portion of the opinion, the unanimous affirmance suggests the panel found no merit in any of the challenges raised.
The production of child pornography charge under 18 U.S.C. § 2251 carries severe penalties, including a mandatory minimum sentence of 15 years and a maximum of 30 years for a first offense. The possession charge under § 2252A carries up to 10 years imprisonment for a first offense. The charge for committing a felony offense involving a minor while required to register as a sex offender under § 2260A adds an additional 10 years to any sentence imposed for the underlying felony.
Sanford's status as a registered sex offender at the time of these offenses significantly enhanced his exposure to lengthy imprisonment. The registration requirement suggests he had prior convictions for sex offenses, which would have influenced both the charges brought and the sentence imposed.
The case highlights the federal government's aggressive prosecution of child exploitation crimes and the severe sentences that can result from convictions on multiple related charges. Federal sentencing guidelines typically recommend lengthy prison terms for child pornography offenses, particularly when they involve production rather than mere possession.
The Western District of Tennessee, where Sanford was originally tried and convicted, has been active in prosecuting federal child exploitation cases. The district court's handling of the case, including its evidentiary rulings and sentencing decision, was fully endorsed by the Sixth Circuit panel.
With the affirmance of his conviction and sentence, Sanford has exhausted his direct appeals unless he seeks review by the Supreme Court, which rarely grants certiorari in criminal cases absent significant legal issues. His next potential avenue for relief would be through a federal habeas corpus petition under 28 U.S.C. § 2255, though such petitions face significant procedural hurdles and are rarely successful.
The decision reinforces the Sixth Circuit's consistent approach to affirming convictions in child exploitation cases where defendants raise evidentiary and sentencing challenges. The court's willingness to uphold the 80-year sentence demonstrates the severe consequences that await those convicted of producing and possessing child pornography, particularly when they have prior sex offense convictions.