U.S. v. Fletcher

Dist. Ct. did not err in sentencing defendant to 30-year term of incarceration on series of child pornography charges that occurred from 2002 to 2009, even though Dist. Ct. grouped some of these offenses and used 2011 sentencing guidelines in effect at time of sentencing for all offenses. Ct. rejected defendant’s argument that use of 2011 guidelines violated Ex Post Facto Clause of Constitution, even though guidelines in effect in 2002 and 2009 were less severe, since under grouping and "one-book" rules, Dist. Ct. could use 2011 guidelines, where defendant had adequate notice that his continued criminal activity would subject him to newer version of guidelines. Moreover, any error in using 2011 guidelines for non-grouped offense was harmless, where sentencing range for said offense was same under both newer and older versions of guidelines.