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United States v. Anderegg

U.S. Court of Appeals for the Seventh Circuit · Federal courts of appeals · · No. 25-1354 · opinion

The Seventh Circuit addresses criminal charges alleging use of Stable Diffusion to create CSAM-like images. It analyzes how federal child-exploitation statutes apply to AI-generated depictions and reverses dismissal of key counts, making the opinion important for AI criminal-law doctrine.

Disposition
The court reversed dismissal of production and possession counts involving AI-generated CSAM and remanded.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Steven Anderegg is charged with pro- ducing, distributing, and possessing visual depictions of mi- nors engaged in sexually explicit conduct and transferring such material to a minor under the age of sixteen. According to the government, Anderegg produced these images using Stable Diffusion, a generative artificial intelligence (“GenAI”) software that allowed him to create hyper-realistic images of prepubescent children engaging in sexually explicit acts. ... When Anderegg moved to dismiss the indictment, the dis- trict court granted the motion as to the possession charge and denied the remainder.

Authorities cited in the passage: 18 U.S.C. § 2258A

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