United States v. Michael John Batt

CourtCourt of Appeals for the Sixth Circuit
DecidedJune 7, 2024
Docket23-1757
StatusUnpublished

This text of United States v. Michael John Batt (United States v. Michael John Batt) 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. Michael John Batt, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0250n.06

Case No. 23-1757

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Jun 07, 2024 ) UNITED STATES OF AMERICA, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF MICHAEL JOHN BATT, ) MICHIGAN Defendant-Appellant. ) ) OPINION

Before: COLE, GIBBONS, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. Michael John Batt struck up an online conversation

with an undercover officer. During the conversation, Batt described sexually abusing his young

daughters. He also sent the officer explicit photos of his children. These events culminated in Batt

pleading guilty to sexual exploitation crimes. On appeal, Batt challenges the procedural and

substantive reasonableness of his within-Guidelines sentence. We affirm.

I.

An undercover officer posted a picture on social media of a young girl holding a man’s

hand with the caption, “Any other local dads out here with similar interests?” Michael John Batt

responded, “Yes.” The officer asked “[w]hat [Batt was] into.” “Incest,” Batt replied. “The more

taboo things. Younger.” Batt said he had done “some touching, rubbing, [and] exploring” with

his children. Batt then asked to switch to a secure messaging application to “go into more details.” No. 23-1757, United States v. Batt

In messages sent over the next few weeks, Batt described his conduct. He recounted in

detail how he touched his daughters sexually while bathing and had them perform oral sex on him.

He also described performing oral sex on them and digitally penetrating them, sometimes while

they slept.

Batt also said he had “a few” “naked pictures” of his daughter, but he tried “to not do

anything overtly obvious.” He said his wife did not know about the abuse, so he had to be “careful”

and “sneaky.” Batt later sent the officer five photos of his daughters in various states of undress.

Law enforcement obtained and executed a search warrant for Batt’s home. There, they

discovered roughly 55,000 files of apparent child pornography on an encrypted hard drive. Batt

agreed to talk with the investigators. He admitted to taking explicit photos of his two daughters,

but he denied sexually abusing them. He claimed his online comments were “just talk.”

Investigators interviewed Batt’s older daughter, who did not report any sexual abuse. His other

daughter was too young to speak with investigators.

Batt pleaded guilty to sexual exploitation of a child and attempted sexual exploitation of a

child, in violation of 18 U.S.C. § 2251(a), (e). The probation office drafted a presentence report

that recommended a two-point enhancement under U.S.S.G. § 2G2.1(b)(2)(A) for commission of

“a sexual act or sexual contact.” After accounting for the mandatory minimum, Batt’s Guidelines

term of imprisonment was 360 months. Batt lodged no objections.

During Batt’s sentencing hearing, the district court noted that, based on the presentence

report, Batt had committed an offense “involving a sexual act or conduct—contact.” Batt again

made no objection. Batt did, however, request a downward variance based on his personal

characteristics. The government opposed, in part because Batt “physically abused his daughters.”

2 No. 23-1757, United States v. Batt

The district court denied the requested variance and sentenced Batt to 360 months of confinement.

The court asked if there were any objections to the sentence; Batt declined.

The district court entered judgment, and this timely appeal followed.

II.

A.1. Batt argues his sentence is procedurally unreasonable because the district court

improperly found that he committed a sexual act or sexual conduct, which triggered a two-level

enhancement. U.S.S.G. § 2G2.1(b)(2)(A). Before addressing this claim, however, we first

determine our standard of review. Batt concedes that he failed to preserve this issue, urging us to

review for plain error. To prevail under that standard, Batt must “show (1) error (2) that was

obvious or clear, (3) that affected [his] substantial rights and (4) that affected the fairness, integrity,

or public reputation of the judicial proceedings.” United States v. Vonner, 516 F.3d 382, 386 (6th

Cir. 2008) (en banc) (cleaned up).

The government labels Batt’s actions as more than mere forfeiture, accusing Batt of

inviting any error and suggesting we decline review absent a “manifest injustice.” See, e.g., United

States v. Akridge, 62 F.4th 258, 263 (6th Cir. 2023). The line between forfeiture and invited error

can be difficult to parse, especially in the sentencing context. See, e.g., id. at 262–64. Here, we

need not weigh in on that delicate question, as Batt’s claim fails even under the more favorable

plain error standard. See, e.g., id.

2. We turn, then, to the merits of Batt’s procedural reasonableness claim. For the two-

level enhancement from § 2G2.1(b)(2)(A) to apply, the government had to prove by a

preponderance of the evidence that Batt committed “a sexual act or sexual contact.” United States

v. Aleo, 681 F.3d 290, 298, 300 (6th Cir. 2012) (citation omitted).

3 No. 23-1757, United States v. Batt

Both parties agree we look to the statutory definitions of “sexual act” and “sexual contact.”

See United States v. Skouteris, 51 F.4th 658, 672 (6th Cir. 2022) (citation omitted); see also

U.S.S.G. § 2G2.1(b)(2)(A) cmt. n.2. A “sexual act” includes “contact between the mouth and the

penis,” penetration of the genitals “by a hand or finger,” and touching of the genitals “to abuse,

humiliate, harass, degrade, or arouse or gratify the sexual desire of any person.” 18 U.S.C.

§ 2246(2). “Sexual contact,” in turn, means “the intentional touching, either directly or through

the clothing, of the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an

intent to abuse, humiliate, harass, degrade, or arouse or gratify the sexual desire of any person.”

Id. § 2246(3).

Here, there were two independent bases for applying § 2G2.1(b)(2)(A). First is the “sexual

act” aspect of the conduct. Consider Batt’s comments to the undercover agent. Batt explained

how he touched and penetrated his daughters’ genitals, performed oral sex on them, and made them

perform oral sex on him. These actions constituted “sexual act[s]” that were relevant conduct for

the purpose of the enhancement. See U.S.S.G. § 1B1.3(a)(1) (defining relevant conduct to include

conduct “that occurred during the commission of the offense of conviction” and “in preparation

for that offense”).

Second, with respect to “sexual contact,” photos depicted Batt’s daughters posing

undressed. The district court fairly inferred both that Batt had touched his daughters’ “genitalia,

anus, groin, breast, inner thigh, or buttocks” to position them for these photos, and that the photos

were made “to arouse or gratify the sexual desire[s]” of Batt and others. See United States v.

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Related

United States v. Aleo
681 F.3d 290 (Sixth Circuit, 2012)
United States v. Vonner
516 F.3d 382 (Sixth Circuit, 2008)
United States v. Shafer
573 F.3d 267 (Sixth Circuit, 2009)
United States v. Richard Parrish
915 F.3d 1043 (Sixth Circuit, 2019)
United States v. William Milliron
984 F.3d 1188 (Sixth Circuit, 2021)
United States v. Rodney Hymes
19 F.4th 928 (Sixth Circuit, 2021)
United States v. George Skouteris, Jr.
51 F.4th 658 (Sixth Circuit, 2022)
United States v. Leonel Ruiz-Lopez
53 F.4th 400 (Sixth Circuit, 2022)
United States v. Stephen Akridge
62 F.4th 258 (Sixth Circuit, 2023)

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United States v. Michael John Batt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-michael-john-batt-ca6-2024.