U.S. v. Courtright

In prosecution on charges of production, possession and receipt of child pornography, Dist. Ct. erred in admitting evidence of defendant's prior sexual abuse conviction involving minor even though Dist. Ct. found that said evidence was admissible under Rule 413. Rule 413 did not apply since defendant had not been charged with offense of sexual assault in instant indictment, and govt. did not otherwise establish that said evidence was admissible under Rule 404(b) on issue of defendant's motive. However, any error was harmless where other evidence (i.e., images of child pornography that were found in computers either owned by defendant or accessible only by defendant) overwhelmingly established defendant's guilt.