Utah Supreme Court reverses child porn convictions over ‘scrapbook’

SALT LAKE CITY — The Utah Supreme Court has reversed part of a former school teacher’s convictions in a ruling about whether scrapbooks he made featuring pornographic images actually broke state law.

In a unanimous ruling, the state’s top court overturned two counts of Michael Scott Hatfield’s conviction. He pleaded no contest in 2017 to charges of sexual exploitation of a minor after being caught at American Preparatory Academy with scrapbooks “containing homemade collages comprised of pornographic images of adults and images of underage, and sometimes nude, girls.”

Hatfield appealed his conviction, claiming that the collages he created did not meet the definition of child pornography under Utah law.

In the ruling, the Utah Supreme Court said the law “unambiguously requires the depiction of an act of sexually explicit conduct that in reality occurred or a depiction of simulated sexually explicit conduct that an average person would perceive as something that appears to have occurred.”

In a graphic ruling, Justice John Pearce said the Court reviewed the scrapbook. Some images did withstand the legal scrutiny and Hatfield’s convictions were upheld. Others, did not.

“These images do not meet the Act’s definition of simulated sexually explicit conduct because they do not duplicate the appearance of an actual act of sexually explicit conduct,” Justice Pearce wrote.

Hatfield is currently serving a one-to-15 year sentence in prison. At his sentencing, his defense attorney blamed some of the activity on Asperger’s syndrome and said he resorted to the sexual activity to cope with social anxiety.

Read the Utah Supreme Court’s ruling here:

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