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Appellant's Brief Regarding Amount-of-Images Enhancement
This brief, filed in the Sixth Circuit, argues that the amount-of-images enhancement to the child pornography guideline violates the separation of powers doctrine because Congress, not the Commission, unilaterally and directly promulgated that enhancement.
2G2.2
Reply to Government
This reply brief in a child pornography case refutes the government's
argument that guidelines based on congressional directives are not properly
subject to scrutiny by district court judges. The reply also supplements
Troy Stabenow's
paper (submitted at an earlier stage in the case) in showing that
the Commission did not act in its characteristic institutional role
in promulgating the child pornography guidelines.
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