The U.S. Court of Appeals for the Eighth Circuit affirmed the sentence of Jessie Michael Collins, who pleaded guilty to two counts of distributing child pornography under federal law. Collins had challenged both the procedural aspects of his sentencing and argued his sentence was substantively unreasonable, but the appellate court rejected both claims.
Collins sent two videos and a still image depicting minors engaged in sexually explicit conduct to an undercover federal agent who was posing as a mother with a prepubescent child. The materials formed the basis for two counts of distribution of child pornography under 18 U.S.C. § 2252(a)(2), to which Collins pleaded guilty.
During the sentencing phase, Collins objected to allegations in his Presentence Report that he had engaged in uncharged sexual conduct with a 12-year-old girl when he was 21 years old. The government called the alleged victim, then a 25-year-old woman, as a witness to testify about these allegations. The district court found her testimony was "completely true" and overruled Collins's objection to including this information in the sentencing calculation.
Based on this finding, the district court applied a five-level enhancement under U.S. Sentencing Guidelines § 2G2.2(b)(5), which provides for an increase "if the defendant engaged in a pattern of activity involving the sexual abuse or exploitation of a minor." This enhancement significantly increased Collins's advisory Guidelines range to 262-327 months.
The case originated in the U.S. District Court for the Eastern District of Arkansas - Central Division. Collins appealed his sentence to the Eighth Circuit, which heard oral arguments on Sept. 15, 2025, and issued its decision on Jan. 14, 2026.
On appeal, Collins raised two primary arguments challenging his sentence. First, he claimed the district court committed procedural error in its sentencing determination. Second, he argued that his sentence was substantively unreasonable given the circumstances of his case.
The Eighth Circuit panel, consisting of Circuit Judges Loken, Kelly, and Erickson, conducted a careful review of both claims in a per curiam opinion. The court systematically examined the procedural aspects of Collins's sentencing, including the district court's application of the sentencing guidelines and consideration of relevant factors.
Regarding the procedural error claim, the appeals court found that the district court had properly followed established sentencing procedures. The court's decision to allow testimony from the alleged victim and to apply the five-level enhancement under the guidelines was within the district court's discretion and supported by the evidence presented.
The substantive reasonableness challenge required the Eighth Circuit to review whether Collins's sentence was appropriate given all the circumstances of his case. Courts of appeals review sentences for reasonableness under an abuse-of-discretion standard, examining both the length of the sentence and the reasoning provided by the district court.
The appeals court found that Collins's sentence fell within an acceptable range considering the serious nature of his crimes and his criminal history. The distribution of child pornography carries severe penalties under federal law due to the exploitation of minors and the perpetuation of harm to victims depicted in such materials.
Federal child pornography distribution cases have become increasingly common as law enforcement agencies conduct undercover operations to identify and prosecute individuals engaged in the exploitation of minors. These investigations often involve agents posing as parents or other adults to identify predators seeking to exploit children.
The application of sentencing enhancements in child pornography cases reflects the federal judiciary's recognition that such crimes often involve broader patterns of predatory behavior. The five-level enhancement applied in Collins's case specifically addresses situations where defendants have engaged in multiple instances of sexual abuse or exploitation of minors.
Child pornography sentences under federal law typically result in substantial prison terms, reflecting both the severity of the underlying crimes and the need to protect potential future victims. The guidelines range of 262-327 months calculated in Collins's case demonstrates the serious consequences facing individuals convicted of these offenses.
The Eighth Circuit's affirmance of Collins's sentence reinforces established precedent regarding the application of federal sentencing guidelines in child pornography cases. The court's careful review of both procedural and substantive challenges ensures that defendants receive appropriate appellate consideration while maintaining the integrity of the sentencing process.
This decision joins numerous other federal appellate rulings that have consistently upheld sentences in child pornography cases where district courts have properly applied the guidelines and considered relevant sentencing factors. The case serves as another example of federal courts' commitment to addressing crimes involving the exploitation of minors through appropriate criminal penalties.