United States v. Stickney

CourtCourt of Appeals for the Tenth Circuit
DecidedOctober 22, 2025
Docket25-8053
StatusUnpublished

This text of United States v. Stickney (United States v. Stickney) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Stickney, (10th Cir. 2025).

Opinion

Appellate Case: 25-8053 Document: 24-1 Date Filed: 10/22/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT October 22, 2025 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 25-8053 (D.C. No. 1:25-CR-00104-KHR-1) ELVY CHARLES STICKNEY, (D. Wyo.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT * _________________________________

Before BACHARACH, PHILLIPS, and EID, Circuit Judges. _________________________________

In July 2025, a grand jury in the District of Wyoming indicted Elvy Charles

Stickney on three charges: two counts of distribution of child pornography in

violation of 18 U.S.C. § 2252A(a)(2)(A), and one count of possession of child

pornography in violation of 18 U.S.C. § 2252A(a)(5)(B). The district court ordered

his pretrial detention. Mr. Stickney appeals. Exercising jurisdiction under 28 U.S.C.

§ 1291 and 18 U.S.C. § 3145(c), we affirm.

After examining the briefs and appellate record, this panel has determined *

unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 25-8053 Document: 24-1 Date Filed: 10/22/2025 Page: 2

I. LAW GOVERNING PRETRIAL DETENTION

The Bail Reform Act allows pretrial detention only if “no condition or

combination of conditions will reasonably assure the appearance of the person as

required and the safety of any other person and the community.” 18 U.S.C.

§ 3142(e)(1). The detention decision must account for four factors:

(1) the nature and circumstances of the offense charged, including whether the offense is a crime of violence . . . or involves a minor victim . . . ; (2) the weight of the evidence against the person; (3) the history and characteristics of the person . . . ; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the person’s release.

Id. § 3142(g).

If the court finds there is probable cause to believe that the defendant

committed certain enumerated offenses, including, as here, an offense involving a

minor victim under 18 U.S.C. § 2252A(a)(2), there is a presumption that no condition

or conditions will reasonably assure the defendant’s appearance and the safety of the

community. See id. § 3142(e)(3)(E). The defendant may rebut that presumption by

producing “some evidence” that he is not a flight risk and that he does not pose a

danger to the community. United States v. Stricklin, 932 F.2d 1353, 1355 (10th Cir.

1991). Even if the defendant rebuts it, the presumption remains a factor in the

court’s detention decision. Id. at 1355. The government must prove flight risk by a

preponderance of the evidence, and it “must prove dangerousness to any other person

2 Appellate Case: 25-8053 Document: 24-1 Date Filed: 10/22/2025 Page: 3

or to the community by clear and convincing evidence.” United States v. Cisneros,

328 F.3d 610, 616 (10th Cir. 2003). 1

II. BACKGROUND

After the grand jury indicted Mr. Stickney, the probation office filed a pretrial

services report, which recommended his pretrial release with conditions. The

government argued for pretrial detention. After a hearing, a magistrate judge ordered

that Mr. Stickney be released under conditions pending trial. The government

appealed. The district court then held a hearing and, after reviewing the matter

de novo, reversed the magistrate judge’s release order.

The district court first determined Mr. Stickney’s distribution of child

pornography charges triggered the presumption that release conditions could not

reasonably assure his appearance or community safety. It then found Mr. Stickney

had proffered sufficient evidence to rebut the presumption but noted that the

presumption remained a factor in its pretrial detention assessment. Next, the court

determined that each of the four § 3142(g) factors weighed in favor of detention.

Ultimately, the district court said that, given those factors and the totality of the

circumstances unique to Mr. Stickney, no condition or combination of conditions

could reasonably assure community safety. It therefore concluded the government

had proved by clear and convincing evidence that Mr. Stickney’s threat to

community safety required detention. Mr. Stickney timely appealed.

1 Flight risk is not an issue in this appeal. 3 Appellate Case: 25-8053 Document: 24-1 Date Filed: 10/22/2025 Page: 4

III. DISCUSSION

“[W]e accept the district court’s findings of historical fact . . . unless they are

clearly erroneous.” Cisneros, 328 F.3d at 613. We review de novo the district

court’s application of the law to the facts, including the ultimate detention decision.

See id.

Mr. Stickney contends the district court “provided no reasoned explanation as

to why conditions could not be fashioned to mitigate [his] dangerousness to the

community.” Aplt. Mem. Br. at 10. Section 3142(g) provides, “in determining

whether there are conditions of release that will reasonably assure the appearance of

the person as required and the safety of any other person and the community, [the

judicial officer shall] take into account the available information concerning” the four

factors. As discussed below, the district court did just that. It determined that each

of the § 3142(g) factors weighed in favor of detention, and therefore concluded that

no release condition or combination of conditions could reasonably assure

community safety.

We disagree with Mr. Stickney’s argument that the district court “failed to

make adequate factual findings to justify [his] detention pending trial.” Aplt. Mem.

Br. at 9. The district court made detailed factual findings as to the four § 3142(g)

factors and Mr. Stickney has not shown that any of those findings were clearly

erroneous.

In determining the nature and circumstances of the offenses weighed in favor

of detention, the district court said that the two distribution charges triggered the

4 Appellate Case: 25-8053 Document: 24-1 Date Filed: 10/22/2025 Page: 5

statutory presumption of detention and all three of the charges were for serious child

pornography offenses with serious consequences.

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Related

United States v. Cisneros
328 F.3d 610 (Tenth Circuit, 2003)
United States v. Jack Moody Stricklin, Jr.
932 F.2d 1353 (Tenth Circuit, 1991)

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