United States v. Khedkar: Deferential Appellate Review and Guideline Enhancements in Undercover Child-Enticement Cases

I. Introduction

United States v. Amol Chandrashekhar Khedkar (11th Cir. No. 24-14203, decided on the non-argument calendar and marked “Not for Publication”) is an appellate sentencing case arising from an online child-enticement sting on the Kik messaging platform. The Eleventh Circuit affirmed a 150‑month sentence—below the advisory Guidelines range but above the 120‑month mandatory minimum—imposed after a guilty plea to attempted enticement of a fictitious eleven-year-old child, in violation of 18 U.S.C. § 2422(b).

Although unpublished and therefore non-precedential under Eleventh Circuit rules, the opinion is instructive in several respects:

• It reaffirms the very high bar for overturning a sentence as substantively unreasonable under the abuse‑of‑discretion standard.
• It confirms that Guideline enhancements for use of a computer and for a victim under twelve are treated as valid and applicable in undercover sting operations, even where the “victim” is fictitious and law enforcement selects the child’s age.
• It applies the doctrine of waiver to bar appellate review of a withdrawn objection to an age-based enhancement, limiting “sentencing manipulation” arguments on appeal.
• It reiterates that the absence of an actual child victim does not require a sentencing discount in § 2422(b) cases, because the key focus is the defendant’s intent.

The decision stands as another illustration of the Eleventh Circuit’s deference to district courts’ weighing of 18 U.S.C. § 3553(a) factors in serious online child exploitation cases, especially where the sentence is below the advisory Guidelines range and far below the statutory maximum of life imprisonment.

II. Factual and Procedural Background

A. The Undercover Kik Operation

The case arises out of an FBI undercover operation on the social media application Kik. In November 2023, an undercover agent posted in a public Kik group, posing as the father of an eleven-year-old girl available for sexual activity.

The defendant, Amol Chandrashekhar Khedkar, using the handle drbrownee, responded and began a private conversation first on Kik, then via text messages. During those communications:

• He asked for pictures and explicit details about the girl, including:
  • Her sexual history,
  • Whether the purported father had engaged in sexual acts with her, and
  • How much the father “charged” for access to the child.
• He made arrangements to meet the father and the girl the following day.
• He asked if he could kiss the girl and inquired whether she liked chocolate.
• He agreed to bring Reese’s cups for the girl.

The next day, Khedkar drove to a prearranged meeting location, a retail store. He parked, exited his car, and began walking toward the entrance, where FBI agents arrested him. In his car, agents found an unopened package of Reese’s cups, consistent with his prior messages.

A forensic search of his cell phone revealed:

• At least 25 Kik conversations discussing the sexual exploitation of children, and
• Evidence that he administered Kik groups whose titles indicated they catered to users interested in sexual activity with children.

The phone also contained at least 80 images of child sexual abuse material; however, the district court expressly declined to consider these images in imposing sentence, an important limiting fact for the sentencing record.

B. Charge and Plea

A federal grand jury indicted Khedkar on one count of:

Attempt to persuade, induce, entice, or coerce a minor under twelve to engage in unlawful sexual activity, in violation of 18 U.S.C. § 2422(b).

Section 2422(b) carries a mandatory minimum of ten years (120 months) and a maximum of life imprisonment.

Khedkar initially litigated motions to suppress his post‑arrest statements and evidence from his cell phone, but ultimately he pled guilty without a plea agreement, thereby abandoning those suppression motions. He received a three-level reduction for acceptance of responsibility.

C. Presentence Investigation Report and Guideline Calculations

The Presentence Investigation Report (“PSR”) applied the November 2023 Sentencing Guidelines and recommended:

• Base offense level: 28 (U.S.S.G. § 2G1.3(a)(3)).
• Specific offense characteristics:
  • +2 levels for use of a computer (§ 2G1.3(b)(3));
  • +8 levels because the offense involved a minor under the age of twelve (§ 2G1.3(b)(5)).
• Adjustment: –3 levels for acceptance of responsibility (§ 3E1.1(a), (b)).

This produced a total offense level of 35. Combined with criminal history category I (reflecting no prior record), the advisory Guideline range was 168 to 210 months of imprisonment.

Initially, Khedkar objected to the eight-level enhancement for a victim under twelve. However, at the sentencing hearing, he withdrew that objection. That withdrawal later became central to the appellate court’s treatment of his “manipulation” argument.

D. Sentencing Arguments in the District Court

At sentencing:

• The government sought a 168‑month sentence (the bottom of the Guidelines range), emphasizing:
  • The defendant’s explicit planning to engage in sex acts with a supposed eleven-year-old,
  • His travel to the meeting site, and
  • His extensive Kik activity involving child sexual exploitation, including his role as an administrator of groups focused on that exploitation.
• Defense counsel requested the statutory minimum of 120 months, acknowledging the seriousness of the offense but stressing:
  • His age (59 at the time of sentencing),
  • Significant health problems (hypertension, hypertrophic cardiomyopathy, chronic ankle and musculoskeletal pain, multiple medications),
  • Lack of prior criminal history,
  • Acceptance of responsibility, and
  • The fact that there was no real child victim, because the supposed father and girl were fictitious.

Defense counsel further argued that the Guideline range was artificially inflated:

• The eight‑level increase for a victim under twelve was triggered solely because law enforcement chose to portray the child as eleven, rather than twelve.
• This choice had a “pretty dramatic” effect: had the “victim” been twelve, the eight-level enhancement would not have applied and the Guideline range would have been much lower.
• Counsel also criticized the computer-use enhancement as irrational in an era when nearly all such crimes are committed online.

The district court questioned the government specifically about these points, noting that the age “on the bubble” between eleven and twelve significantly affected the Guidelines. The government replied that the enhancement was correctly applied and that the proximity to age twelve was not in itself a basis for a variance.

E. The Sentence Imposed

The district court:

• Adopted the PSR calculations and the Guideline range of 168 to 210 months.
• Described the offense as an “extremely serious crime,” emphasizing that:
  • Khedkar had actually traveled to engage in what he believed would be sexual activity with an eleven-year-old, and
  • It could easily have been a real child and real victim.
• Reviewed the § 3553(a) factors, including:
  • The nature and circumstances of the offense,
  • The defendant’s history and characteristics (age, health, lack of record, “responsible position in the community”),
  • The need for just punishment, deterrence, and protection of the public, and
  • Consistency with sentences imposed in comparable enticement cases.
• Commented that the computer-use enhancement applied “in virtually 100 percent of the cases” and often formed a basis for a variance—but still chose a sentence “in the vicinity of the guideline range.”
• Concluded that the mandatory minimum 120‑month sentence, though substantial, was insufficient given the § 3553(a) factors and facts.

The court ultimately imposed:

• 150 months’ imprisonment (a downward variance from 168 months, but 30 months above the statutory minimum), and
• Ten years of supervised release.

Defense counsel objected to the “reasonableness” of the sentence, preserving a substantive reasonableness challenge for appeal.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit, in a brief per curiam opinion, affirmed the sentence in full. The key holdings and rationales can be summarized as follows:

1. Standard of Review: The court reviewed the sentence for substantive reasonableness under a deferential abuse-of-discretion standard (United States v. Boone; United States v. Curtin). The defendant bears the burden to show that the sentence is unreasonable in light of the § 3553(a) factors.
2. Deference to District Court’s Weighing of § 3553(a): The panel emphasized that sentencing courts have “substantial discretion” in how they weigh the various factors, and an appellate court may not reverse simply because it would have chosen a different sentence (United States v. Howard; United States v. Irey).
3. Reasonableness of the 150‑Month Sentence: Given:
   • The seriousness of the conduct,
   • Evidence of other online activity involving child sexual exploitation,
   • The need for deterrence and protection of the public,
   • The sentence being below the advisory Guidelines range and far below the statutory maximum,
   the court held it could not say the sentence was “truly unreasonable” (Irey; United States v. Coglianese).
4. Guideline Enhancements Not “Irrational” or Manipulated:
   • The defendant did not dispute that the Guideline range was correctly calculated.
   • He had affirmatively withdrawn his objection to the eight-level enhancement for a victim under twelve, thereby waiving appellate review of any challenge to that enhancement or to the alleged “manipulation” by law enforcement (United States v. Horsfall).
   • The court noted that his claim that the computer-use and age enhancements were “irrational” or manipulated did not undermine the correctness of the Guideline calculation.
5. No Discount for Fictitious Victim: The court rejected the argument that the absence of a “real” child victim required a lower sentence, relying on United States v. Murrell, which held that an age-based enhancement targets the defendant’s intent, not actual harm, and that there is “no difference between an undercover officer victim and a fictitious victim” for this purpose.
6. Mitigating Factors Were Considered: The record showed that the district court did consider the defendant’s age, health, lack of criminal history, and arguments about the enhancements; it simply weighed them differently than the defense advocated, which is well within the court’s discretion (Howard).
7. Sentencing Statistics Not Controlling: Khedkar’s reliance on broad sentencing statistics was unpersuasive because the district court’s individualized consideration of the § 3553(a) factors governs.

On this record, the panel concluded that—after giving “a full measure of deference” to the sentencing judge—it could not find a “definite and firm conviction” that the district court committed a clear error of judgment. The sentence was therefore affirmed.

IV. Detailed Analysis

A. Precedents and Doctrinal Framework

1. Substantive Reasonableness and the Abuse-of-Discretion Standard

Several cited precedents set out the governing standards:

• United States v. Boone, 97 F.4th 1331 (11th Cir. 2024): Reiterates that substantive reasonableness is reviewed under a deferential abuse-of-discretion standard. Appellate courts may vacate a sentence “only if we are left with the definite and firm conviction that the district court committed a clear error of judgment in weighing the § 3553(a) factors.”
• United States v. Curtin, 78 F.4th 1299 (11th Cir. 2023): Emphasizes that the defendant has the burden of proving that a sentence is substantively unreasonable.
• United States v. Steiger, 107 F.4th 1315 (11th Cir. 2024): Confirms that substantive reasonableness is judged in light of the “totality of the facts and circumstances” and the statutory sentencing factors in § 3553(a).
• United States v. Howard, 28 F.4th 180 (11th Cir. 2022): States that sentencing courts have “substantial discretion” in weighing the § 3553(a) factors, and appellate courts do not reweigh them anew.
• United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc): A seminal en banc decision (also involving serious sexual offenses against minors) that articulates the “full measure of deference” standard. It instructs that an appellate court may not set aside a sentence merely because it would have chosen a different one; it may do so only if the sentence is truly outside the range of reasonable sentences based on the record.

These authorities collectively undergird the panel’s central move: treating the case as a paradigmatic example of a district judge acting well within the bounds of discretion when imposing a below-Guidelines sentence in a grave child-exploitation case.

2. Indicators of Reasonableness: Below-Guidelines and Below-Maximum Sentences

The panel also cites:

• United States v. Coglianese, 34 F.4th 1002 (11th Cir. 2022): Holds that a sentence below the advisory Guidelines range and far below the statutory maximum is “indicative of reasonableness,” though not dispositive.

In Khedkar, the sentence:

• Is 18 months below the bottom of the 168‑ to 210‑month Guidelines range, and
• Is far below the life-imprisonment maximum authorized by § 2422(b).

The panel expressly notes these factors as supporting the conclusion that the sentence is within the range of reasonable outcomes, particularly in light of:

• The serious nature of the offense, and
• Comparable or harsher sentences that the Eleventh Circuit has sustained in similar § 2422(b) prosecutions.

3. Comparable § 2422(b) Case: United States v. Nagel

The panel cites:

• United States v. Nagel, 835 F.3d 1371 (11th Cir. 2016): There, the Eleventh Circuit upheld a 292‑month sentence at the bottom of the Guidelines range for enticement of a minor under § 2422(b).

In comparison:

• Khedkar’s 150‑month sentence is much shorter than the sentence in Nagel,
• Yet both involve egregious conduct aimed at sexually exploiting minors.

This demonstrates that the 150‑month term falls well within the range of sentences the Eleventh Circuit has previously deemed reasonable for similar conduct. In that sense, Nagel functions as a benchmark against which Khedkar appears comparatively lenient, further undercutting any claim of substantive unreasonableness.

4. Waiver by Withdrawal of Objections: United States v. Horsfall

On the question of “manipulation” of the Guideline range, the panel relies on:

• United States v. Horsfall, 552 F.3d 1275 (11th Cir. 2008): Holds that when a defendant affirmatively withdraws a sentencing objection, that issue is waived, not merely forfeited, and thus is not subject even to plain‑error review on appeal.

In Khedkar:

• The defendant initially objected to the eight-level enhancement for the victim’s age under § 2G1.3(b)(5), claiming that law enforcement artificially set the age at eleven.
• At sentencing, he chose to withdraw that objection.
• On appeal, he tried to resurrect that theory in slightly different form by arguing that the Guidelines were “manipulated” via “fictitious” details supplied by the undercover officer.

Citing Horsfall, the panel holds that this is waived and therefore unreviewable. Strategically, this underscores for defense counsel that once a Guideline objection is withdrawn at sentencing, it cannot later be repackaged as an appellate claim of “irrationality” or “manipulation” of the same enhancement.

5. Fictitious Victims and the Age Enhancement: United States v. Murrell

Perhaps the most conceptually important citation is:

• United States v. Murrell, 368 F.3d 1283 (11th Cir. 2004): Addressed an age-based enhancement in a similar sting context. It held that:
  • The enhancement is “directed at the defendant’s intent, rather than any actual harm caused to a genuine victim.”
  • Accordingly, “there is no difference between an undercover officer victim and a fictitious victim.”

In Khedkar, the defendant argued that the absence of a real child victim should compel a lower sentence. The Eleventh Circuit rejected this outright, invoking Murrell to reaffirm that:

• The Guidelines and statutory structures for § 2422(b) focus on what the defendant intended to do, not on whether law enforcement allowed the harm to occur.
• Therefore, a defendant who travels to meet what he believes is an eleven-year-old for sexual activity is just as culpable under the Guidelines as one who actually meets an eleven-year-old, even though the latter scenario could entail additional victim-impact considerations.

This doctrine is critical for sting operations: it insulates sentences from arguments premised on the lack of actual harm when a sting successfully prevents the abuse from occurring.

B. The Court’s Legal Reasoning Applied to the Facts

1. Evaluating the § 3553(a) Factors

The district court, and the Eleventh Circuit in reviewing it, gave major weight to several § 3553(a) factors:

• Nature and circumstances of the offense:
  • Explicit sexual discussions about an eleven-year-old girl.
  • Negotiation of access and price with the purported father.
  • Specific arrangements to meet the minor, including a grooming-type detail (bringing candy).
  • Actual travel to the meeting spot and approach to the store entrance.
  • Additional evidence of ongoing online activity concerning child sexual exploitation.
• History and characteristics of the defendant:
  • No prior criminal record.
  • Advanced age and health problems.
  • A “responsible position in the community.”
• The need for the sentence to:
  • Reflect the seriousness of the offense,
  • Promote respect for the law,
  • Provide just punishment,
  • Afford adequate deterrence (both specific and general), and
  • Protect the public from further crimes of the defendant.
• Avoidance of unwarranted sentencing disparities:
  • The court remarked that the defendant’s circumstances were “not unusual” for enticement cases, suggesting a desire to align with typical sentencing patterns in similar cases.

The Eleventh Circuit acknowledges that the district court grappled with the “dramatic” impact of the under‑twelve enhancement and the near‑universality of the computer-use enhancement, but nonetheless concluded that a sentence “in the vicinity of the guideline range” was necessary to serve the statutory purposes of sentencing. This reflection and explicit acknowledgment undercut any suggestion that the court blindly followed the Guidelines.

2. Below-Guidelines, But Above the Mandatory Minimum

A central question on appeal was whether the district court erred in declining to go all the way down to the statutory minimum (120 months), instead choosing 150 months. The Eleventh Circuit’s reasoning proceeds as follows:

• The sentence is already a downward variance from the Guidelines range of 168 to 210 months.
• Because of the “extremely serious” nature of the offense and the surrounding evidence of deviant interest in children, the court found that a mere ten-year sentence would be inadequate to punish, deter, and protect the public.
• Given the deference owed to the district court’s judgment on how to balance these factors, and considering that 150 months is:
  • Substantially below what the Guidelines recommended, and
  • Far below life imprisonment,
  the panel concluded that the sentence falls squarely within the broad band of reasonable outcomes.

In other words, the court’s reasoning reflects a two-layered deference:

1. To the district court’s choice to use the Guidelines as a benchmark and impose a sentence near, but below, the range; and
2. To the substantive judgment that a ten-year sentence would understate the seriousness and risk posed by the defendant’s conduct.

3. Treatment of Mitigating Factors

The opinion directly addresses the defendant’s claim that the district court failed to account for:

• His age,
• His health conditions,
• His lack of prior criminal history, and
• The absence of an actual child victim.

The Eleventh Circuit notes that the sentencing judge explicitly discussed these factors and still chose to impose 150 months. Under Howard, the fact that the court did not give them the weight the defendant preferred does not mean they were ignored or that the sentence is unreasonable.

This is an important doctrinal point: appellate review of substantive reasonableness is not a rebalancing exercise. So long as the district court:

• Identifies and considers the relevant § 3553(a) factors, and
• Explains its reasoning in a coherent, non-arbitrary fashion,

the appellate court will rarely find an abuse of discretion merely because one could reasonably weigh the factors differently.

4. Rejection of the “No Real Victim” Argument

With the support of Murrell, the Eleventh Circuit firmly reaffirms that:

• The focus of § 2422(b) and the relevant Guidelines is the defendant’s intent and actions to commit the offense.
• Online sting operations using fictitious minors are a permissible and recognized enforcement tool; the lack of an actual child does not diminish the defendant’s culpability for attempting to commit the crime.

This is particularly important in light of modern law enforcement strategies, where nearly all § 2422(b) prosecutions are based on undercover operations rather than on actual completed abuse. The opinion signals that:

• Courts will not treat sting cases as categorically less serious for sentencing purposes.
• Defendants cannot rely on the government’s intervention (which prevented actual harm) as a mitigating fact sufficient, by itself, to justify a large downward variance.

5. Sentencing Statistics vs. Individualized Sentencing

Khedkar also relied on “broad sentencing statistics” to claim that his sentence was outside the norm. The Eleventh Circuit finds this unpersuasive for two main reasons:

• § 3553(a) mandates an individualized assessment based on the defendant’s conduct and characteristics, not mere averages.
• Given the gravity of his specific offense and evidence of further deviant interest, general averages cannot override the district court’s case‑specific judgment.

This aligns with broader federal sentencing jurisprudence: while national statistics can be relevant background, they generally cannot overcome a careful case-specific analysis by a district judge.

C. Impact and Future Implications

1. For Defendants and Defense Counsel

• Objections must be preserved: Withdrawing an objection to an enhancement—such as the age‑under‑twelve enhancement—constitutes waiver, foreclosing appellate review of that issue. Defense counsel should carefully consider the strategic consequences before withdrawing any objection to Guideline calculations.
• “No real victim” arguments have limited traction: Given Murrell and now the reiteration in Khedkar, defendants in undercover sting cases face an uphill battle arguing that the fictitious nature of the minor should substantially reduce the sentence.
• Challenging the computer-use enhancement is difficult: The district court acknowledged that the computer enhancement applies almost universally in modern sex‑offense cases, but still treated the Guidelines as an important benchmark. While some judges might use this as a basis for variance, appellate courts are unlikely to require such variances.
• Statistics are not decisive: Citing national or circuit-wide averages will rarely, standing alone, establish substantive unreasonableness when a district judge clearly explains the individualized rationale.

2. For Prosecutors and Law Enforcement

• Law enforcement’s age selection is judicially tolerated: The opinion reinforces that choosing an age under twelve in a sting—thereby triggering an eight-level enhancement—is not, by itself, impermissible “manipulation,” particularly when the Guideline calculation is not properly challenged.
• Undercover stings remain fully supported: The Eleventh Circuit’s reaffirmation that intent, not actual harm, drives the age enhancement further legitimates undercover tactics in the § 2422(b) context.
• Online activity evidence is highly relevant: Evidence of additional child-exploitation conversations and group administration, even if not charged separately, can significantly influence the sentencing court’s perception of risk and culpability.

3. For District Judges

• Thoughtful discussion of the Guidelines and § 3553(a) is key: The affirmance here underscores that when a district court:
  • Calculates the Guidelines correctly,
  • Identifies the key mitigating and aggravating factors, and
  • Explains why a particular sentence is sufficient but not greater than necessary,
  the Eleventh Circuit will almost always defer, especially where the sentence is below or within the Guidelines range.
• Recognition of controversial enhancements is permitted: The district court’s open acknowledgment that the computer-use enhancement applies in nearly all such cases—and is often a reason for variances—demonstrates that judges may critically evaluate the Guidelines without abandoning them as a reference point.
• Non-precedential but indicative of circuit trends: Although unpublished, the opinion aligns with a line of Eleventh Circuit cases reflecting a generally tough approach to child sexual exploitation offenses and a broad zone of deference to district courts in that domain.

V. Complex Concepts Simplified

1. Substantive Reasonableness

When a defendant appeals a sentence, they can argue:

• Procedural unreasonableness (e.g., miscalculating the Guidelines, not considering § 3553(a), relying on clearly erroneous facts), and/or
• Substantive unreasonableness (even if the procedure was fine, the sentence is so long or so short that it is outside the range of reasonable choices).

Substantive reasonableness asks: Did the judge choose a sentence that is “sufficient but not greater than necessary” in light of all the factors, or did the judge clearly go too far in one direction? This is reviewed under an abuse-of-discretion standard, meaning the appellate court will overturn the sentence only if it is firmly convinced the judge made a serious error in judgment.

2. Abuse-of-Discretion Standard

Under abuse of discretion review:

• The appellate court does not ask what sentence it would impose.
• Instead, it asks whether the district judge’s decision:
  • Fell outside the range of reasonable options, or
  • Was based on a misunderstanding of law or clearly erroneous facts.

In practice, this means reversal is rare—especially when the sentence is within or below the Guidelines range.

3. Federal Sentencing Guidelines in Plain Terms

The Sentencing Guidelines work like a scoring system:

• Every federal crime has a base offense level (here, 28).
• Certain facts add points:
  • Using a computer: +2 levels.
  • Victim under twelve: +8 levels.
• Defendants who plead guilty and accept responsibility usually get a 2–3 level reduction.

The final total offense level is then combined with the defendant’s criminal history category in a table to yield a recommended range of months. Judges must consider this range but are not strictly bound by it.

4. Mandatory Minimum vs. Guidelines Range

• Mandatory minimum (here, 120 months) is the lowest sentence the court can impose by law (absent substantial-assistance or safety-valve provisions, not applicable here).
• The Guidelines range (here, 168–210 months) is advisory and usually higher than the minimum for serious crimes.

The judge may sentence:

• At the mandatory minimum (if below the Guidelines),
• Within the Guidelines range, or
• Above the Guidelines (upward variance), as long as he or she justifies the choice under § 3553(a).

5. Fictitious Victims in Sting Operations

In many internet sting cases:

• The “child” is an undercover officer or a made-up persona.
• The law treats a defendant’s attempt to commit the crime (enticement) as almost as serious as if the child were real, because:
  • The danger and the defendant’s intent are fully present.

As Murrell explains, for age-based enhancements, it does not matter that no real child was present; the enhancement is meant to punish the intent to assault a particularly young child.

6. Waiver vs. Forfeiture

• Forfeiture is failing to make a timely objection. Courts sometimes review forfeited issues for “plain error.”
• Waiver is the intentional relinquishment of a known right, such as:
  • Raising an objection and then affirmatively withdrawing it.

Waived issues are generally unreviewable on appeal. In Khedkar, the defendant waived any challenge to the eight-level age enhancement by withdrawing his PSR objection at sentencing.

VI. Conclusion

United States v. Khedkar, though unpublished, provides a clear window into the Eleventh Circuit’s current approach to sentencing in online child-enticement cases:

• It strongly reaffirms a deferential abuse-of-discretion standard for reviewing below-Guidelines sentences, especially in the sensitive area of child sex offenses.
• It underscores that Guideline enhancements for computer use and for victims under twelve remain fully operative and are not deemed “irrational” simply because they apply often or because law enforcement selected the specific age in a sting.
• It confirms that undercover, fictitious victims are treated the same as real victims for purposes of age-based enhancements and the seriousness of the offense, focusing squarely on the defendant’s intent.
• It illustrates the practical importance of preserving objections; withdrawing a Guideline objection at sentencing will bar later appellate claims that the enhancement was manipulated or unfair.
• It positions a 150‑month sentence (12.5 years)—below the advisory range but above the minimum—as comfortably within the band of reasonable outcomes for § 2422(b) offenses, particularly where there is evidence of broader sexual interest in children.

In the broader legal landscape, Khedkar aligns with a well-established Eleventh Circuit trend: serious child-exploitation offenses, even in attempt or sting form, justify substantial terms of imprisonment; Guidelines enhancements in this area are robust; and appellate courts will rarely disturb a district court’s carefully reasoned sentence absent a clear and serious error of judgment.