United States v. Jarrod Sanford

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 7, 2026
Docket24-5994
StatusUnpublished

This text of United States v. Jarrod Sanford (United States v. Jarrod Sanford) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Jarrod Sanford, (6th Cir. 2026).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0013n.06

No. 24-5994

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 07, 2026 ) KELLY L. STEPHENS, Clerk UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE WESTERN JARROD SANFORD, ) DISTRICT OF TENNESSEE Defendant-Appellant. ) ) OPINION

Before: BOGGS, BUSH, and READLER, Circuit Judges.

BOGGS, Circuit Judge. A jury convicted defendant Jarrod Sanford of production of child

pornography, in violation of 18 U.S.C. § 2251(a)&(e), possession of child pornography, in viola-

tion of 18 U.S.C. § 2252A(a)(5)(B), and committing a felony offense with a minor while being

required to register as a sex offender, in violation of 18 U.S.C. § 2260A. He was sentenced to 960

months of imprisonment.

On appeal, Sanford argues that the district court erred in admitting evidence that he had

raped and sexually abused the child victim on other occasions than the ones charged, that it com-

mitted plain error in permitting certain testimony regarding the victim’s out-of-court statements.

He also contends that his sentence is procedurally and substantively unreasonable, and that there

was insufficient evidence to support his conviction for production of child pornography and com-

mitting that offense while being required to register as a sex offender.

For the reasons below, we affirm the judgment of the district court in its entirety. No. 24-5994, United States v. Sanford

BACKGROUND

In November 2023, Jarrod Sanford was a twice-convicted child-sex offender, required by

the State of Tennessee to register as a child-sex offender. He was also on federal supervised re-

lease. As a condition of his supervised release, Sanford was required to enroll any internet-capable

device he possessed in the probation office’s computer-monitoring program. Sanford had enrolled

one device, a Samsung Android cell phone.

Sanford lived with the thirteen-year-old victim, Anna, in November, 2023 and for several

years earlier.1 Sanford began sexually abusing Anna when she was about ten years old. He first

raped her when she was about eleven years old. He continued to sexually abuse her, including

raping her vaginally, orally, and anally every other day. Anna initially reported the abuse to a

friend and the friend’s father in January, 2023. Police were contacted, came and took Anna’s

phone, and interviewed her, but nothing came of Anna’s report.

Sanford began raping her again six months later. Anna disclosed this abuse to another

friend. That friend reported the disclosure to a school counselor, who called the police. When the

police arrived at Sanford’s home in November, 2023, Sanford gave Anna a silver phone and asked

her to hide it. This phone was not the Samsung Android cell phone that Sanford had enrolled in

the monitoring program.

Anna told responding officers that Sanford had been raping her, that there was a scratch on

her leg from the rape, that he had a phone that the probation officer did not know about, that he

told her to hide the phone, and that there were probably photographs on the phone of Sanford

raping her. Anna also reported that Sanford had raped her the night before, orally and vaginally,

and had ejaculated on her breasts.

1 Anna is a pseudonym.

-2- No. 24-5994, United States v. Sanford

The officers seized the phone, took Anna for a sexual-assault examination by a sexual-

assault nurse, and took her for an interview.

The phone contained photographs of the penile-oral rape of Anna by Sanford. Anna iden-

tified herself and Sanford in the photographs. Anna’s mother also identified Sanford and Anna in

the photographs. The photos were taken on a sofa in the living room in the house where Sanford

and Anna lived. A forensic examination of the phone revealed connections to Sanford’s Google

accounts, social media accounts, email address, and phone number. It also contained text messages

in which Sanford identified himself and sent a “selfie”-style photo to another person. The phone

also contained searches and views of simulated child pornography similar to the photographs of

Sanford raping Anna as well as the other instances of rape.

Anna’s sexual-assault exam revealed tears in her vagina, bruising on her left forearm and

upper thighs, and scratches on her leg. The sexual-assault nurse also took swabs for DNA analysis

from Anna’s cervix and breasts. DNA testing revealed those samples were a match to Sanford.

Sanford was charged with production of child pornography, in violation of 18 U.S.C.

§2251(a)&(e), possession of child pornography, in violation of 18 U.S.C. § 2252A(a)(5)(B), and

committing the production offense while required to register as a sex offender, in violation of 18

U.S.C. § 2260A. A jury convicted Sanford of all three charges. The district court also found that

Sanford had violated his supervised release. He was sentenced to 960 months of imprisonment,

with a consecutive two-year sentence for the supervised-release violation. Sanford now appeals.

-3- No. 24-5994, United States v. Sanford

ANALYSIS

Sanford argues that (1) the district court abused its discretion by admitting evidence of his

prior rapes of Anna and a limited selection of his pornographic searches, (2) the district court

plainly erred in admitting out-of-court statements between Anna’s friend Bella2 and Anna, in

which Anna disclosed Sanford’s ongoing sexual abuse, (3) his sentence was procedurally and sub-

stantively unreasonable, and (4) there was insufficient evidence to convict him of the three of-

fenses.

A. The district court did not abuse its discretion in admitting evidence related to Sanford’s uncharged conduct.

We review “evidentiary rulings concerning relevance and admissibility for an abuse of

discretion,” taking “a maximal view of the evidence’s probative effect and a minimal view of its

unfairly prejudicial effect.” United States v. Brown, 367 F.3d 549, 554 (6th Cir. 2004) (internal

citations and quotations omitted).3 If the evidence was erroneously admitted, we then ask whether

the admission was harmless error or whether it requires reversal of the conviction. United States

v. Martinez, 588 F.3d 301, 312 (6th Cir. 2009).

1. Evidence Regarding Other Rapes of Anna

Sanford first objects to the admission of evidence regarding Sanford’s rapes of Anna other

than those depicted in the child pornography, including Anna’s testimony and physical evidence

2 Bella is also a pseudonym. 3 The appellee appropriately notes that there is an intra-circuit conflict regarding the appropriate standard of review for Rule 404(b). Certain panels have utilized a three-step approach, applying different levels of scrutiny to each of the three steps of the 404(b) analysis.

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