United States v. Hoover, No. 22-4322 (4th Cir. 2024)
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In 2019, Michael Scott Hoover was arrested on multiple counts of indecent liberties with a minor. Subsequent investigations led to the discovery of videos and images of child pornography on his work-issued iPhone. The videos depicted two minors, both relatives of Hoover, engaging in explicit sexual conduct. Hoover was subsequently indicted on two counts of child pornography production and one count of possession of child pornography. Following a trial, Hoover was convicted on all counts and sentenced to 840 months' imprisonment. He appealed his conviction and sentence, raising several arguments.
The United States Court of Appeals for the Fourth Circuit rejected all of Hoover's claims and affirmed his conviction and sentence. The court held that the trial court did not err in its evidentiary rulings, denial of Hoover's Rule 29 motion for judgment of acquittal, or in instructing the jury on the elements of child pornography production. The court also found that the district court did not err in sentencing Hoover to 840 months' imprisonment. The court found sufficient evidence supporting Hoover's child pornography production convictions, including the specific-intent and interstate-nexus elements of the offenses. The court also rejected Hoover's challenges to the procedural reasonableness of his sentence, finding that the district court had adequately explained its conclusion that the sentence was not unfairly harsh for Hoover.
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