Local activity can still support prosecution for creating child pornography

U.S. v. West, 2014 WL 3906842 (8/12/14) (Okl.) (unpub'd) - Prosecution for creating child porn in violation of 18 U.S.C. § 2251(a) did not contravene the Commerce Clause even if the defendant deleted all the images and never intended to distribute them interstate. Congress could decide such local activities constitute an essential part of the interstate market for child porn.