In the case of Stephen Chesser versus the State of Florida, Mr. Chesser was charged with nine counts of possession of photographs depicting sexual conduct by a child with intent to promote. All nine photographs were found in a shed located on some property belonging to Mr. Chesser's parents. Chesser later pled guilty to all nine counts but then appealed his sentence.
On appeal, he argued that because all nine photos were discovered in one search, there was only one episode of promotion, and therefore only one conviction for the above-stated crime was legally permissible. The court of appeals agreed with Chesser and ordered the lower court to dismiss eight of the nine counts.