United States v. Buchanan
United States Court of Appeals for the Fifth Circuit
485 F.3d 274 (2007)
Army Corps of Engineers park ranger Joseph Buchanan (defendant) was found by his supervisor to have downloaded, via a single work computer, images including four larger files depicting minors engaged in sexually explicit conduct along with numerous thumbnail images, all located together in his temporary internet folder from apparently the same webpage visit; separately, encrypted files on his hard drive contained additional pornographic images. Buchanan was convicted of four separate counts of receiving child pornography (one per larger image file) plus a separate possession count for the hard-drive images, and he appealed the four receipt convictions as multiplicitous.
Whether a defendant's downloading of multiple child pornography images, apparently received simultaneously from a single webpage visit, may support separately punishable receipt convictions for each individual image absent evidence of distinct acts to obtain each one.