1. Petitioner was convicted 18 U.S.C. § 1466A(a)(1) of a child pornography offense for a hand drawn cartoon image on his computer involving no real or real looking person. This statute prohibits "knowingly ... possess[ing] with intent to distribute, a visual depiction of any kind, including a drawing, [or] cartoon … that depicts a minor engaging in sexually explicit conduct and is obscene."
The first question presented is whether § 1466A(a)(1) violates the First Amendment as applied to mere hand drawn pure cartoon images that depicted no real, real looking children, computer generated images, AI, or deepfakes under Ashcroft v. Free Speech Coalition, New York v. Ferber, nor Miller v. California.

2. A forensic search of Petitioner's computer showed approximately 300 images of child sexual abuse material in the "carved space" of Petitioner's computer hard drive. The proof showed, however, it could not be accessed by him without a utilities program, which he did not have. There was no proof at trial how it got there, who downloaded it, or whether he even accessed it at all.
The second question presented is whether this is a complete failure of proof by the government making Petitioner's conviction for possession of child pornography in violation of due process clause of the Fifth Amendment.

Whether 18 U.S.C. § 1466A(a)(1), as applied to hand-drawn cartoon images depicting minors in sexually explicit conduct, violates the First Amendment under Ashcroft v. Free Speech Coalition, and whether conviction for possession of child sexual abuse material found in an inaccessible carved space of a computer hard drive, with no proof of access or intent, violates the Due Process Clause of the Fifth Amendment