United States of America v. Lamara Allen Thompson

Seattle, Washington criminal defense lawyer represented the Defendant charged with production of child pornography.



An individual convicted under 18 U.S.C. § 2251(a) for production of child pornography is subject to a mandatory

term of imprisonment of at least 15 years. Under 18 U.S.C. § 2251(e), that mandatory term is increased to at least 25

years if that individual "has one prior conviction ... under the laws of any State relating to aggravated sexual abuse, sexual abuse, [or] abusive sexual contact involving a minor or ward.”



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Lamar Allen Thompson ("Thompson”) was convicted for production and possession of child

pornography. He now challenges the 28-year term of imprisonment that the district court imposed for his

convictions. First, Thompson contends that a 2016 Washington child molestation conviction should not have

triggered a 10-year increase to his mandatory minimum sentence. We disagree and hold that the Washington statute

under which Thompson was convicted is either a categorical match to, or at least relates to, the predicate generic offenses in 18 U.S.C. § 2251(e), thus triggering the increase. Second, Thompson argues that the district court erred by declining to recommend whether Thompson should serve his federal sentence concurrently with certain anticipated state

sentences. But because Thompson did not make this argument in the district court, we must apply plain error review. And we conclude that the district court's decision not to make any recommendation was not plain error.

Affirmed