Livingood v. United States

CourtDistrict Court, E.D. Kentucky
DecidedMay 1, 2024
Docket5:23-cv-00262
StatusUnknown

This text of Livingood v. United States (Livingood v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Livingood v. United States, (E.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION (at Lexington)

UNITED STATES OF AMERICA, ) ) Plaintiff/Respondent, ) Criminal Action No. 5: 22-001-DCR ) and V. ) Civil Action No. 5: 23-262-DCR ) CHRISTOPHER WAYNE ) LIVINGOOD, ) MEMORANDUM OPINION ) AND ORDER Defendant/Movant. )

*** *** *** *** Defendant Christopher Livingood was sentenced to 360 months’ imprisonment after pleading guilty to producing child pornography in violation of 18 U.S.C. § 2251(a). However, he recently filed a motion to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. § 2255, claiming ineffective assistance of counsel. [Record No. 56] Livingood’s motion will be deny motion because he has failed to establish an error of constitutional magnitude, including the deprivation of the effective assistance of counsel as guaranteed by the Sixth Amendment to the United States Constitution. I. Livingood came to the FBI’s attention during its investigation of Diana Roe, an individual who served as the administrator of a Kik Messenger group that involved child sexual abuse and bestiality material.1 A review of Roe’s Kik account revealed that she exchanged

1 Roe pleaded guilty to one count of distribution and receipt of child pornography and was sentenced to 180 months’ imprisonment. United States v. Roe, et al., 1: 19-CR-299 (S.D. Ind. Jan. 8, 2021). visual depictions of minors engaged in sexually explicit conduct with multiple Kik users, including “bryan388.” User bryan388 sent Roe at least one image depicting an adult male, whom bryan388 reported to be himself, engaged in sexually explicit conduct with a child. Kik

user bryan388 further reported to Roe that he had sexually abused at least two children to whom he had access. Authorities identified bryan388 as Defendant Livingood following an investigation which concluded in 2021. A forensic examination of Livingood’s phone revealed Kik conversations between Roe and Livingood that occurred between January 2018 and June 2019 in which they discussed committing child sexual abuse and bestiality. Livingood sent Roe numerous sexually explicit images of minors engaged in sexual activity with adults and at least two sexually explicit

images of a male infant in his care. Livingood was charged with producing (Count 1), distributing (Counts 2 and 3), receiving (Counts 4 and 5), and possessing (Count 6) child pornography in January 2022. Attorney Christopher Spedding was appointed under the Criminal Justice Act to represent Livingood. Following an approximate two-month trial continuance that Spedding requested so that he could review the voluminous discovery in the case, Livingood filed a motion for re-

arraignment. Livingood pleaded guilty to Count 1 on May 27, 2022, pursuant to a written plea agreement. [Record Nos. 24, 25] On September 16, 2022, Livingood was sentenced to the statutory maximum sentence (360 months’ imprisonment), followed by a life term of supervised release. Counts 2 through 6 of the indictment were dismissed on motion of the United States and pursuant to the parties’ plea agreement. II. Livingood has filed a timely motion to vacate, correct, or set aside his sentence pursuant to 28 U.S.C. § 2255 based on claims of ineffective assistance of counsel. To prevail on such

a claim, the movant must establish that counsel’s performance was constitutionally deficient and that he was prejudiced by the deficient performance. Strickland v. Washington, 466 U.S. 668, 687 (1984). To demonstrate that counsel’s performance was constitutionally deficient, a defendant must show that counsel’s representation fell below an objective standard of reasonableness. Id. at 688. Courts must be highly deferential in evaluating counsel’s performance and there is a “strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance.” Id. at 688-90. A defendant seeking to establish

ineffective assistance of counsel must prove his claim by a preponderance of the evidence. Pough v. United States, 442 F.3d 959, 964 (6th Cir. 2006). A. Livingood first argues that attorney Spedding was ineffective for failing to properly investigate his charge of producing child pornography. However, he does not indicate what additional investigation he believes Spedding should have performed. Instead, he insists that

his conviction is based on “innocent” events that occurred when he was babysitting his infant grandson in 2017. Livingood reports that, while changing the infant’s diaper, he discovered that “tiny, clear moisture-absorbing beads” had expelled from the diaper and onto the “baby’s midsection.” Livingood contends that he simply “attempted to photograph the tiny beads” with his cell phone camera because he was annoyed with the situation. But it is unclear what additional investigation attorney Spedding could have performed to verify Livingood’s claimed motivation for taking photographs of the infant’s genital region. The United States has tendered an affidavit from attorney Spedding indicating that Spedding spent over 35 hours reviewing discovery and met with Livingood approximately eight times. Spedding noted in his affidavit that an argument could be made that the photographs of

Livingood’s grandson were benign—but only if they were viewed in isolation. Consistent with Spedding’s observation, Livingood’s claim concerning the innocent nature of the images is undermined by substantial evidence in the record, which he notably omits from his motion. This includes contemporaneous Kik messages in which Livingood advised Roe that he would “have the baby tomorrow all day” and described his plans to sexually abuse the infant. Livingood also sent Roe numerous other images depicting child sexual abuse and described to Roe his sexual abuse of the infant and another child in graphic

detail. Relatedly, Livingood claims that the images he produced were not sexually explicit and were not made for the purpose of creating child pornography. 2 This argument is at odds with Livingood’s plea agreement pursuant to which he admitted employing or using a minor to engage in sexually explicit conduct for the purpose of producing a visual depiction of that conduct. [Record No. 25] Nevertheless, the Court will further address why the two images at

issue constitute sexually explicit conduct and were made for the purpose of creating child pornography.

2 Claims that can be presented on direct appeal but are not are forfeited and cannot be considered in a § 2255 motion. United States v. Frady, 456 U.S. 152 (1982). Livingood forfeited the claims discussed in the remainder of this subsection by failing to raise them on appeal. However, to the extent he contends that Spedding was ineffective for failing to raise these issues on appeal, the Court has addressed them for the sake of thoroughness. Sexually explicit conduct includes lascivious exhibition of the genitals or pubic area of any person. 18 U.S.C. § 2256. As the defendant correctly notes, courts within the Sixth Circuit apply a multifactor test to determine whether an image is lascivious. See United States v.

Brown, 579 F.3d 672, 680 (6th Cir.

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Related

United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
David Wayne Baker v. United States
781 F.2d 85 (Sixth Circuit, 1986)
Thomas L. Ludwig v. United States
162 F.3d 456 (Sixth Circuit, 1998)
Lance Pough v. United States
442 F.3d 959 (Sixth Circuit, 2006)
Robert Campbell v. United States
686 F.3d 353 (Sixth Circuit, 2012)
Henry Hodges v. Stanton Heidle, Warden
727 F.3d 517 (Sixth Circuit, 2013)
United States v. Brown
579 F.3d 672 (Sixth Circuit, 2009)
United States v. Dost
636 F. Supp. 828 (S.D. California, 1986)

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