UNITED STATES OF AMERICA v. CHARLES BERNARD LONG
The Eleventh Circuit affirmed Charles Long's 78-month sentence for child pornography possession, ruling that while the district court erred in applying a 75-image-per-video rule, the mistake did not affect Long's substantial rights. The court held that applying the correct one-frame-one-image standard would likely result in a significantly higher image count, meaning no reasonable probability exists that a lower sentence would have been imposed.