United States v. Anthony Chiccini

CourtCourt of Appeals for the Third Circuit
DecidedApril 6, 2022
Docket21-1036
StatusUnpublished

This text of United States v. Anthony Chiccini (United States v. Anthony Chiccini) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Anthony Chiccini, (3d Cir. 2022).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 21-1036 _____________

UNITED STATES OF AMERICA

v.

ANTHONY CHICCINI, Appellant _____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2:18-cr-00255-001) District Judge: Honorable Eduardo C. Robreno _____________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) January 24, 2022 _____________

Before: CHAGARES, Chief Judge, McKEE and MATEY, Circuit Judges.

(Filed: April 6, 2022)

_____________________

OPINION _____________________

CHAGARES, Chief Judge.

 This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Anthony Chiccini pled guilty to three counts of possessing and receiving child

pornography and was sentenced to 235 months of imprisonment. Chiccini argues that the

District Court incorrectly calculated his sentencing guidelines range by failing to apply a

two-level offense reduction under United States Sentencing Commission Guidelines

Manual (the “Guidelines” or “U.S.S.G.”) § 2G2.2(b)(1) for individuals convicted of

receipt but who did not distribute or intend to distribute the material. We will vacate

Chiccini’s sentence and remand for resentencing for the reasons we explain below.

I.

In 2018, Adobe Systems Inc. submitted nine tips to the National Center for

Missing and Exploited Children regarding an Adobe account belonging to 73-year-old

Chiccini that contained “numerous images depicting child pornography.” Presentence

Report (“PSR”) ¶ 7. The case was referred to the Federal Bureau of Investigation

(“FBI”), which conducted a search of Chiccini’s residence. After a forensic examination,

the FBI uncovered over 1,300 images on Chiccini’s desktop computer, smartphone,

laptop, and Adobe Cloud account. Chiccini was charged with three counts of possessing

and receiving child pornography (hereinafter, “the material” or “the depictions”). Counts

One and Two charged a violation of 18 U.S.C. § 2252(a)(2) for “receipt” of the material,

and Count Three charged a violation of 18 U.S.C. § 2252(a)(4)(B) for “possession” of the

material. Chiccini pled guilty to both the receipt and possession offenses.

“Receipt” carries steeper penalties than “possession” under 18 U.S.C. § 2252.

Unlike simple possession, which has no statutory mandatory minimum, receipt carries a

five-year mandatory minimum sentence. 18 U.S.C. § 2252(b)(1). The two offenses are

2 also treated differently in the Guidelines. The Guidelines provide a base offense level of

18 for possession and 22 for receipt. U.S.S.G. § 2G2.2(a). But a defendant convicted of

receipt has an opportunity to receive a two-level reduction in his base offense level if his

“conduct was limited to the receipt or solicitation of material involving the sexual

exploitation of a minor” and he “did not intend to traffic in, or distribute, such material.”

Id. § (b)(1).

The PSR calculated Chiccini’s base offense level at 22 pursuant to U.S.S.G. §

2G2.2(a)(2). It then recommended several enhancements that brought the final adjusted

offense level to 37. The PSR did not, however, recommend a two-level reduction

pursuant to U.S.S.G. § 2G2.2(b)(1). Neither party objected to the PSR’s calculation, and

the District Court adopted it. With a final offense level of 37, the Guidelines range was

235-293 months of imprisonment. Had two levels been subtracted pursuant to §

2G2.2(b)(1), the range would have been 188-235 months.

The District Court imposed a sentence of 235 months of imprisonment, which

was at the bottom of the Guidelines range but above the mandatory minimum. Chiccini

timely appealed his sentence.

II.1

Pursuant to Federal Rule of Criminal Procedure 52(b), we review the District

Court’s failure to apply the two-level Guidelines reduction for plain error because

Chiccini failed to raise the issue before the District Court. See United States v. Aguirre-

1 The District Court had jurisdiction pursuant to 18 U.S.C. § 3231. We have appellate jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742.

3 Miron, 988 F.3d 683, 687 (3d Cir. 2021). Under plain-error review, the defendant must

demonstrate that there is: “(1) an error, (2) that is plain, and (3) that the plain error affects

his substantial rights.” Id. In most cases, the phrase, affects substantial rights “means

that the error must have been prejudicial: [i]t must have affected the outcome of the

district court proceedings.” United States v. Olano, 507 U.S. 725, 734 (1993). Once all

three prongs are met, we may exercise our discretion to correct the error if it “seriously

affects the fairness, integrity or public reputation of judicial proceedings.” Rosales-

Mireles v. United States, 138 S. Ct. 1897, 1905 (2018) (quoting Molina-Martinez v.

United States, 578 U.S. 189, 914 (2016) (citations omitted)).

A district court must begin every sentencing by “correctly calculating the

applicable Guidelines range.” Gall v. United States, 552 U.S. 38, 49 (2007). We have

emphasized that “a correct Guidelines calculation is crucial to the sentencing process . . .

and have admonished that because the Guidelines still play an integral role in criminal

sentencing . . . the entirety of the Guidelines calculation [must] be done correctly.”

United States v. Boney, 769 F.3d 153, 159 (3d Cir. 2014) (cleaned up).

Regardless of the ultimate sentence, an error in calculating the Guidelines range

“can, and most often will, be sufficient to show a reasonable probability of a different

outcome absent the error.” Molina-Martinez, 578 U.S. at 198; see also United States v.

Payano, 930 F.3d 186, 190 (3d Cir. 2019). With respect to the “fairness and integrity”

portion of plain error review, the Supreme Court has made clear that the “risk of

unnecessary deprivation of liberty particularly undermines the fairness, integrity, or

public reputation of judicial proceedings in the context of a plain Guidelines error

4 because of the role the district court plays in calculating the range and the relative ease of

correcting the error.” Rosales-Mireles, 138 S. Ct. at 1908.

A.

The two-level reduction in § 2G2.2(b)(1) applies where “the evidence did not

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