July 20, 2026·25-1986·Panel Decision·BRENNAN, Chief Judge·By James Taylor
The Seventh Circuit affirmed the conviction of Andrew Boltz for sexual exploitation of a minor, upholding evidentiary rulings regarding the victim's sexual history and the defendant's prior conduct.
Boltz met a sixteen-year-old victim on Omegle in January two thousand twenty and exchanged sexually explicit messages and photographs. Law enforcement was alerted after the victim’s mother discovered the relationship.
The court’s reasoning
The court held that Federal Rule of Evidence 412 barred evidence of the victim sending photos to other men. Evidence of Boltz grooming another minor was admissible under Federal Rule of Evidence 404(b). The district court did not act in bad faith regarding evidence preservation.
What it means going forward
Conviction stands; evidentiary standards for sexual offense cases clarified regarding victim history and prior bad acts.
