USA v. Jonathan Tanguay

2013 DNH 147P
CourtDistrict Court, D. New Hampshire
DecidedNovember 7, 2013
DocketCR-11-173-JL
StatusPublished

This text of 2013 DNH 147P (USA v. Jonathan Tanguay) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v. Jonathan Tanguay, 2013 DNH 147P (D.N.H. 2013).

Opinion

USA v . Jonathan Tanguay CR-11-173-JL 11/7/13 P

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal N o . 11-cv-173-JL Opinion N o . 2013 DNH 147P Jonathan Tanguay

MEMORANDUM ORDER

A jury in this court recently found the defendant, Jonathan

Tanguay, guilty of one count of possessing child pornography.

See 18 U.S.C. § 2252A(a)(5)(B). After receiving a report from a

visitor to Tanguay’s home that Tanguay had displayed images of

child pornography on his laptop computer, the New Hampshire State

Police secured a warrant to search the home for those materials.

This search allegedly turned up images of child pornography on

the computer’s hard drive, as well as on an external hard drive

and a compact disc also seized from Tanguay’s home. See United

States v . Tanguay, 907 F. Supp. 2d 165 (D.N.H. 2012) (denying

Tanguay’s motion to suppress the fruits of the search).

This court conducted two jury trials on the charge against

Tanguay: one in October 2013, which ended in a conviction, and

an earlier trial in March 2013, which ended in a mistrial. Prior

to the first trial, Tanguay filed a motion in limine seeking to

exclude various items of evidence. See L . C r . R. 12.1(c). This

court granted the motion in part and denied it in part in a written order. United States v . Tanguay, 2012 DNH 197 (the

“Prior Order”). Before the second trial, Tanguay filed two more

motions in limine, seeking to exclude various other items of

evidence, much of which the prosecution had not sought to

introduce in the first trial. This evidence consisted

principally of other materials allegedly found on Tanguay’s

computer, including (1) stories graphically describing sexual

encounters between male adults and male children, (2) sexually

suggestive, but not necessarily pornographic, photographs of

either male children or young-looking male adults, located in a

folder called “On-Line Friends,” (3) pornographic photographs of

an 18-year old male identified as “Jared” that Tanguay had shown

to a witness who testified at trial, and (4) “bookmarks” to

websites with names that suggest sexually explicit material

featuring male children.1

1 Tanguay also sought to exclude photographs, also found in his possession, of a trial witness--who was involved in an amorous relationship with Tanguay between late 2008 and late 2009--at the witness’s senior prom. The prosecution did not seek to introduce those photographs at trial. Tanguay further sought to exclude evidence of this witness’s age, objecting that it was unfairly prejudicial because he was only 18 years of age at the time the two began their relationship, but the court denied that motion based on the prosecution’s agreement to adduce the witness’s age only at the time of the trial, rather than at the time he became romantically involved with Tanguay. While Tanguay maintained that even the witness’s age at the time of trial was unfairly prejudicial, the court disagreed.

2 Tanguay argued that, because his possession of these

materials amounts to “other acts,” this evidence is inadmissible,

Fed. R. Evid. 404(b)(1), and that, in any event, its probative

value is substantially outweighed by the danger of unfair

prejudice, Fed. R. Evid. 403. The prosecution, however, argued

that this evidence was admissible to show, among other things,

Tanguay’s knowledge that he possessed the child pornography

allegedly found on his computer, Fed. R. Evid. 404(b)(2), and

that its probative value on that point--which was a crucial issue

at trial--outweighed any risk of unfair prejudice under Rule

403. 2 The court heard oral argument on Tanguay’s motions prior

to trial, then announced its rulings from the bench during a

break in the proceedings before the jury, just after trial had

commenced. This written order serves to explain those rulings in

greater detail.

Under Rule 404(b), “[e]vidence of a crime, wrong, or other

act is not admissible to prove a person’s character to show that

on a particular occasion the person acted in accordance with the

character,” but “may be admissible for another purpose, such as

proving motive, opportunity, intent, preparation, plan,

2 Importantly, the evidence the prosecution sought to adduce was not admissible under either Rule 413 or Rule 414 of the Federal Rules of Evidence, because Tanguay was not accused of “sexual assault” or “child molestation” as those terms are defined by those rules.

3 knowledge, identity, absence of mistake, or lack of accident.”

And Rule 403 allows the court to “exclude relevant evidence if

its probative value is substantially outweighed by a danger of

. . . unfair prejudice.”

Synthesizing these rules, the Court of Appeals has “adopted

a two-part test to determine the admissibility” of evidence of

the defendant’s other acts. United States v . Aguilar-Aranceta,

58 F.3d 796, 798 (1st Cir. 1995).

First, the trial judge must determine whether the evidence in question is offered for any purpose other than solely to prove that the defendant had a propensity to commit the crime in question[,] [t]hat i s , . . . has some ‘special’ probative value. Prior bad acts may be ‘specially relevant’ if they are probative of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.

If the judge is satisfied that the proffered evidence has ‘special relevance,’ the focus shifts to the second part of the test, which applies Rule 403 to determine whether the probative value of the evidence is substantially outweighed by the danger of unfair prejudice.

Id. (footnote and further quotation marks omitted).

Applying this test, the court ruled at trial that Tanguay’s

possession of the additional materials found on his computer is

relevant to his knowledge that he possessed the images of child

pornography found on that computer (as well as on the external

hard drive and the CD also seized from his home). Fed. R. Evid.

404(b)(2). The court also ruled that any risk of unfair

4 prejudice from Tanguay’s possession of these other materials did

not outweigh the evidence’s probative value. Fed. R. Evid. 403.

Rule 404(b)

To find a defendant guilty of possessing child pornography,

the jury must find, among other things, that the defendant

“knowingly possesse[d] . . . material that contains an image of

child pornography.” 18 U.S.C. § 2252A(a)(5)(B). In his opening

statement, counsel for Tanguay focused on this element of the

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