DOUBLE COUNTING: THE APPROPRIATE APPLICATION OF THE VULNERABLE VICTIM ENHANCEMENT FOR CHILD SEX OFFENDERS.

The article discusses the U.S. Fourth Circuit court decision in the case 'United States v. Dowell' which involves the production and transportation of child pornography. It discusses the Sentencing Guidelines Manual and the vulnerable victim enhancement. It argues that the court in Dowell case could have alternatively applied the vulnerable victim enhancement because the victims were vulnerable, not due to their age, but due to left without parental supervision.