The Court of Appeals in Roberts v. U.S., decided on September 26, 2019, reversed multiple unlawful-disclosure convictions due to erroneous jury instructions. The unlawful disclosure, a relatively new statute in DC renders unlawful disclosure of certain graphic photographic or video materials.  In this day and age of electronic capture, transfer of data and images, the statute has become more and more relevant and applicable. Specifically, the unlawful-disclosure statute provides in pertinent parts that it shall be unlawful for a person to knowingly disclose one or more sexual images of another identified or identifiable person when: The person depicted did not
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