United States v. Christopher Daniels

── United States v. Christopher Daniels ── Court: Court of Appeals for the Third Circuit Date: April 21, 2026 Category: General NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________ No. 24-2615 ____________ UNITED STATES OF AMERICA v. CHRISTOPHER DANIELS, Appellant ____________ On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2:23-cr-00021-001) District Judge: Honorable Juan R. Sánchez ____________ Submitted Pursuant to Third Circuit L.A.R. 34.1(a) December 9, 2025 ____________ Before: KRAUSE, PHIPPS, and CHUNG, Circuit Judges (Filed: April 21, 2026) ____________ OPINION* ____________ PHIPPS, Circuit Judge. While on supervised release for a conviction of child pornography possession, a Philadelphia man did not appear to have complied with the sex offender registration requirements under SORNA, the Sex Offender Registration and Notification Act, see 18 U.S.C. § 2250. Federal law enforcement officers obtained a warrant to search the house * This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. where they believed the man was living for evidence of his reporting violations, and as part of that search, they discovered child pornography on the man’s electronic devices. After an additional investigation revealed much more child pornography, the man was charged with and convicted on five counts related to the receipt of, possession of, and access with intent to view child pornography, see id. § 2252(a)(2), (a)(4)(B), (b)(1)–(2), as well as one count of failure to register as a sex offender in violation of SORNA, see id. § 2250. He received a 15-year (180-month) sentence followed by a 15-year term of supervised release subject to several conditions. The man now challenges four rulings associated with those convictions and the resulting sentence. First, he contends that the warrant allowing the search of his residence for evidence of SORNA violations was overbroad and the information obtained from that warrant’s challenged provisions should have been suppressed. Second, at trial, the man attempted to blame his housemate brother for downloading the child pornography, and in response to relevance and hearsay objections, the District Court did not allow the brother to be questioned about child pornography on his devices. The man now attacks that ruling as a violation of his Sixth Amendment rights. Third, the man asserts that under the Double Jeopardy Clause, U.S. Const. amend. V, he could not be convicted of both access to and possession of the same images and that he could not be convicted of both possession and receipt of the same images. Finally, he submits that the District Court erred in imposing two supervised-release conditions – that he make financial disclosures to his probation officer and that his electronic devices be monitored and subject to inspection for 15 years. For the reasons below, we will affirm the judgment and the sentence imposed by the District Court. 2  BACKGROUND In November 2011, while Christopher Daniels, then age 21, was living on West Lehigh Avenue in Philadelphia with his older brother, Shaun Daniels, they were investigated for possession of child