United States v. Williams

Michael Williams (defendant) posted a message in a public internet chat room offering to exchange child pornography with other users, then privately exchanged images with an undercover Secret Service agent and offered to trade material he claimed was child pornography for similar material from the agent. When the agent did not produce anything, Williams posted a link to child pornography in the public chat. A subsequent search of his home turned up child pornography. Williams was charged with both possessing and pandering child pornography under a federal statute criminalizing the advertising, distribution, or solicitation of child pornography, or material claimed to be such. He pleaded guilty but reserved the right to challenge the constitutionality of the pandering charge.

Whether the First Amendment protects an offer to provide or receive material believed or claimed to be child pornography.