Duncan Jason Smith, Petitioner v. State of Florida, Respondent

Summary

The court held that using a file-sharing program to make child pornography accessible to an authorized recipient constitutes transmitting child pornography under the plain meaning of the governing statute. By loading the images into a shared file and granting the recipient access, Smith sent the images and caused them to be delivered. The court approved the Fourth District's decision and rejected the contrary interpretation that had applied the rule of lenity.