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Robert Wayne Hutton v. United States

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 24-2202 · judgment November 17, 2025


Certiorari denied · June 29, 2026
Pre-decision estimate: 7% cert probability (95% interval 5%–10%)

Before the decision, about 1.8× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Ninth Circuit decision below, and a petition filed soon after the judgment below.

Question presented

18 U.S.C. § 2251(a) makes it a crime to “use[] ... any minor to engage in ... any sexually explicit conduct for the purpose of producing any visual depiction of such conduct.” “[S]exually explicit conduct” is defined to include “lascivious exhibition of the ... genitals[] or pubic area of any person.” 18 U.S.C. § 2256(2)(A). Petitioner took surreptitious videos of a nude minor getting in and out of the shower. The minor did not know she was being filmed and she engaged in no sexual conduct. The question presented, on which there is an acknowledged circuit conflict, is: Whether, as a matter of law, secretly recording a minor’s ordinary and routine nonsexual activity falls outside the scope of 18 U.S.C. § 2251(a)?

Counsel of record

For petitioner
E. Joshua Rosenkranz
Orrick, Herrington & Sutcliffe LLP

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Proceedings

  1. Jun 29 2026
    Petition DENIED.
  2. Jun 09 2026
    DISTRIBUTED for Conference of 6/25/2026.
  3. Jun 05 2026
    Reply of petitioner Robert Wayne Hutton filed. (Distributed)
  4. May 20 2026
    Brief of respondent United States in opposition filed.
  5. Apr 01 2026
    Motion to extend the time to file a response is granted and the time is further extended to and including May 20, 2026.
  6. Mar 31 2026
    Motion to extend the time to file a response from April 20, 2026 to May 20, 2026, submitted to The Clerk.
  7. Mar 17 2026
    Motion to extend the time to file a response is granted and the time is extended to and including April 20, 2026.
  8. Mar 16 2026
    Brief amici curiae of Federal Public and Community Defender Organizations of the Ninth Circuit filed.
  9. Mar 13 2026
    Motion to extend the time to file a response from March 20, 2026 to April 20, 2026, submitted to The Clerk.
  10. Feb 13 2026
    Petition for a writ of certiorari filed. (Response due March 20, 2026)