Samuel Crabtree v. Commonwealth of Kentucky

Summary

The Court affirmed Crabtree's convictions arising from partially downloaded child-pornography videos but reversed the convictions based on still images found only in the computer's automatically generated thumbnail cache. The video evidence showed that Crabtree affirmatively selected and began downloading files whose names clearly indicated child pornography, while the cache evidence did not establish when or how the still images were acquired or that Crabtree knowingly possessed them. The Court also held that innocent possession can be a defense in limited circumstances, but Crabtree was not entitled to that instruction on the evidence presented, and the remaining alleged instructional, evidentiary, and cumulative errors were harmless or nonexistent.