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Otterson takes issue with the brevity of the district court’s discussion of the 18 U.S.C. § 3553(a) factors and argues the district court failed to consider or properly weigh important factors; we reject his arguments. While we will continue to urge sentencing courts to provide ample discussion for our review, we have held that the mechanical recitation of sentencing factors is unnecessary. United States v. Boleware, 498 F.3d 859, 862 (8th Cir.2007) ( “ ‘[W]hen a judge decides simply to apply the Guidelines to a particular case, doing so will not necessarily require lengthy explanation.’ ” (quoting Rita, 127 S.Ct. at 2468)). Here, the court reviewed the PSR (to which Otterson made no objections), listened to Otterson’s and the government’s arguments, imposed the sentence with express discussion of the factors deemed most pertinent to the case, and proceeded to impose a lengthy series of special conditions related to treatment programs and future conditions on release. Finally, Otterson argues specifically that his lengthy sentence fails to honor the goal of minimizing sentencing disparity among similarly situated defendants. He also argues that the district court improperly relied on general studies presented by the government about pedophiles and the large number of crimes that some such offenders purportedly commit prior to detection. Regarding sentencing disparity, Otterson’s criminal history revealed a prior, similar offense, but he has not demonstrated other offenders so similarly situated or with such disparate sentences as to make his own sentence unreasonable. Regarding the studies, there is no suggestion the district court relied on the general information Otterson finds objectionable. In whole, the sentencing transcript does not reveal that the district court considered improper factors, failed to consider important factors, or clearly erred in the weighing of those factors. Jones, 493 F.3d at 940. At Otterson’s sentencing hearing, Otterson emphasized the fact that he came from a troubled home, he was the victim of sexual abuse, his father sexually abused his sisters, and his mother was committed for mental health issues while Otterson was still a minor. He discussed his own well-documented history of physical and mental disabilities, including the fact that he suffered from Bell’s palsy which, together with other conditions, Otterson claimed made social contact difficult and ensured he lived essentially as a hermit. Finally, he admitted that he had been using drugs at the time of the offense. Based on Otterson’s plea agreement and undisputed factual assertions in the Presentence Investigative Report (“the PSR”), the facts of Otterson’s offense and related conduct were as follows. Otterson transported images over the Internet to an undercover officer who was posing as a thirteen-year-old girl, and the images depicted prepubescent minors or minors under the age of twelve engaged in sexual intercourse or oral sex with adult males. In addition, Otterson exposed himself via the Internet to the undercover officer and solicited contact with the undercover officer. He also suggested it had been two years since his last sexual encounter with a minor, and he referenced a desire for girls as young as five to nine years old. While executing a search warrant at Otterson’s residence, officers discovered and seized computer files that contained more than ten but fewer than 150 images of child pornography, some of which displayed sadistic or masochistic conduct and children under the age of twelve. Otterson argued primarily that his social history and physical and mental infirmities provided justification for a lower sentence. He also argued that because he did not actually produce child pornography or physically touch any children related to the present offense, his sentence should not be at the top of the Guidelines range. Finally, he argued that his criminal history was overstated given his characterization of his prior property offenses as minor and his light sentence on the Missouri sex crime charge.Otterson’s base offense level for the present crimes was twenty-two, and he received the following upward adjustments under the Guidelines: two levels because the pornographic materials involved prepubescent minors or minors who had not attained the age of twelve, U.S.S.G. § 2G2.2(b)(2); five levels because his offense involved distribution to an undercover agent he believed to be a minor, § 2G2.2(b)(3)(C); four levels because the material portrayed sadistic or masochistic conduct, § 2G2.2(b)(4); two levels because the offense involved the use of a computer, § 2G2.2(b)(6); and two levels because the offense involved at least ten but fewer than 150 images, § 2G2.2(b)(7)(A). He received a three-level downward adjustment for acceptance of responsibility under § 3E1.1(a) and (b), resulting in a total offense level of thirty-four and an overall advisory Guidelines range of 188-235 months’ imprisonment.

Otterson’s criminal history consisted primarily of convictions for burglary and theft-related offenses, most of which involved property of little value and some of which merited no criminal history points given the age of the convictions. He did, however, have a more recent conviction under Mo.Rev.Stat. § 566.090, “Sexual misconduct in the first degree,” for engaging in sexual contact with a clothed child. The offense was a misdemeanor punishable by up to one year of imprisonment, and he received a sentence of forty-five days’ imprisonment. The facts of the prior offense involved Otterson’s presence at a clubhouse used by neighborhood children, his repeated interaction with the children, and his eventual inappropriate touching of a ten-year-old child between her legs. This led to an altercation with the girl’s father and Otterson’s arrest. The district court in the present case found Otterson had five criminal history points placing him in criminal history Category III.Kevin D. Otterson pled guilty to Transporting Child Pornography and Possessing Child Pornography in violation of 18 U.S.C. §§ 2252A(a)(1) and (a)(5)(B), respectively. The district court imposed a sentence at the top of an uncontested Guidelines range, 235 months’ imprisonment, followed by a lifetime of supervised release. Otterson appeals, arguing only that his sentence is unreasonable. We affirm.Following arguments, the district court imposed the sentence of 235 months to be followed by supervised relief for life. The district court specifically stated its view as to the severity of the offense, referenced the sadistic and masochistic nature of the materials, and referenced Otterson’s online discussions with the undercover officer who posed as a thirteen-year-old girl. The district court stated the sentence was appropriate “to address the sentencing objectives of just punishment, general deterrence, and incapacitation.” The district court did not expressly address other factors under 18 U.S.C. § 3553(a) or discuss the issues Otterson raised as mitigating factors. Otterson argues the district court failed to consider the issues he identified as mitigating factors, such as his mental and physical condition, his social history, the absence of physical contact with a minor in the present offense, his acceptance of responsibility, and the fact that he did not create the materials at issue in this case. All of these issues, however, were clearly presented to the court in the PSR and at the sentencing hearing and are accounted for in the undisputed Guidelines range. “[T]hat range was fashioned taking into account the factors set forth at 18 U.S.C. § 3553(a).” United States v. Two Shields, 497 F.3d 789, 796 (8th Cir.2007). Further, some of these issues-the fact that he did not produce the materials and that he did not have physical contact with a minor-serve primarily to demonstrate that Otterson was not shown to be guilty of a greater offense. They do not demonstrate that his within-range sentence is unreasonable. Under the federal common law of the Ninth Circuit, contractual provisions limiting an air carrier’s liability for lost or damaged goods are “prima facie valid if the face of the contract (or, in this case, air waybill) recites the liability limitation and ‘the means to avoid it.’ “ Read-Rite, 186 F.3d at 1198,quoting Royal Insurance, 50 F.3d at 727 (9th Cir.1995).“The burden then shifts to the shipper to prove that it did not have a ‘fair opportunity’ to purchase greater liability coverage.”Id., quoting Royal Insurance, 50 F.3d at 727. Here, the airbill clearly states the liability limitation and sets forth the ways in which it can be avoided: either by declaring a value higher than $100 and paying a correspondingly higher amount for shipping the goods, or, in the event (as here) that the terms of the contract do not permit declaration of a sufficiently high value, by purchasing third-party insurance. There is no evidence in the record to support the conclusion that Otterson lacked a fair opportunity to purchase adequate liability coverage. The liability-limiting provisions are therefore enforceable as a matter of law.Recognizing the inapplicability of the preemption doctrine to the claims against the Doe defendants, some or all of whom are alleged to be employees of either FedEx or Kinko’s, Otterson argues that the named defendants are vicariously liable for their employees’ tort under Oregon’s respondeat superior doctrine. According to Oregon law:

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Now before the court are the motion for summary judgment (# 32) filed by defendants FedEx and Kinko’s and the motion for summary judgment (# 44) filed by plaintiff Otterson. I have considered the parties’ motions, oral argument on behalf of the parties, and all of the pleadings on file. For the reasons set forth below, the defendants’ motion should be granted and Otterson’s motion should be denied.

The Ninth Circuit has observed that “[a] traditional example of the artful pleading doctrine is one in which the defendant has a federal preemption defense to a state claim and federal law provides a remedy.” Brennan, 134 F.3d at 1409 (internal quotation marks omitted), quoting Sullivan v. First Affiliated Sec., Inc., 813 F .2d 1368, 13712 (9th Cir.1987). The Brennan court analyzed state law causes of action for unlawful business practices and breach of contract, determined that they were preempted by the Internal Revenue Code, but determined that, because the IRC provided a cause of action for seeking tax refunds, and the claims were effectively the equivalent of suits for tax refunds, the claims were inherently federal. See id. at 1409-1412.
On its face, Otterson’s amended complaint articulates precisely two claims, each expressly stating a cause of action under the common law of the State of Oregon. “In general, district courts have federal-question jurisdiction only if a federal question appears on the face of a plaintiffs complaint.” Brennan v. Southwest Airlines Co., 134 F.3d 1405 (9th Cir.1998) (emphasis original), citing Louisville & Nashville R.R. Co. v. Mottley, 211 U.S. 149, 152 (1908). However, the so-called “artful pleading doctrine” provides an exception to this general rule:

Under the doctrine of respondeat superior, an employer is liable for an employee’s torts when the employee acts within the scope of employment. Negligence or other tortious conduct by the employer is not required….
This court has examined the pending motion and the underlying record. No clear error appears on the face of the record. The Findings and Recommendation is, therefore, adopted. Accordingly, plaintiff’s Motion for Summary Judgment [44] is DENIED and defendants’ Motion for Summary Judgment [32] is GRANTED. Plaintiff’s remaining claim is remanded to the Circuit Court of the State of Oregon, County of Multnomah, for further proceedings.Chesterman v. Barmon, 305 Or. 439, 442 (1988) (citations omitted). Here, the record contains no evidence from which a trier of fact could reasonably conclude that a FedEx or Kinko’s employee was either hired for the purpose of converting FedEx customers’ property or converted Otterson’s watch while motivated, even in part, by a purpose of serving his or her employer. As a matter of law, Ott
erson’s entirely speculative vicarious liability argument therefore fails.

(Ellipsis original.) Within the next half hour, Otterson replied, “OK, I’ll Fedex it Monday for Tuesday delivery. If everything looks OK just pop me a check in the mail.”Otterson’s amended complaint states a cause of action for conversion against FedEx, Kinko’s, and eight individual Doe defendants. Under the unambiguous language of the Act’s preemption clause and the clear holdings of Wolens, Read-Rite, and Majors, Otterson’s state-law causes of action against FedEx and Kinko’s, other than “routine” breach of contract claims, cannot go forward in this or any other court.See49 U.S.C. § 41713(b)(4)(A); Wolens, 513 U.S. at 222, 232-233; Read-Rite, 186 F.3d at 1195, 1197; Majors, 117 F.3d at 930-931.

However, the same conclusion does not apply to Otterson’s conversion claim as pled against the individual Doe defendants. To the extent Otterson alleges that any individual Doe defendant converted the contents of the FedEx package for his or her own personal gain, a claim seeking to establish such defendant’s direct liability for such conversion would not in any material way “relate [ ] to a price, route, or service of an air carrier.”49 U .S.C. § 41713(b)(4)(A). Because the claim alleging the Doe defendants’ direct liability for conversion is not within the scope of the Act’s preemption provision, the conversion claim should survive federal preemption to the sole extent alleged against the Doe defendants.
a State … may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of an air carrier … when such carrier is transporting property by aircraft or by motor vehicle (whether or not such property has had or will have a prior or subsequent air movement).

In consequence, Otterson is limited as a matter of law to a maximum recovery of $100 on his federal common law claim. As defendants have already tendered that amount, such claim should be dismissed as moot.
Courts should “invoke the doctrine ‘only in limited circumstances as it raises difficult issues of state and federal relationships and often yields unsatisfactory results.’ “ Sullivan [ v. First Affiliated Secur., Inc.], 813 F.2d [1368,] 1373 [ (9th Cir.1987) ] (quoting Salveson v. W. States Bankcard, 731 F.2d 1423, 1427 (9th Cir.1984)). While the artful pleading doctrine is a useful procedural sieve to detect traces of federal subject matter jurisdiction in a particular case, it also has substantive implications on the scope of federal jurisdiction and efficiency. See generally Arthur R. Miller, Artful Pleading: A Doctrine in Search of Definition, 76 Tex. L.Rev. 1781 (1988) (discussing the history of artful pleading doctrine and the implications of doctrinal expansion on federal jurisdiction).

This action was filed on August 1, 2007, by plaintiff Kevin Otterson in the Circuit Court of the State of Oregon, County of Multnomah, alleging a single claim of conversion against defendant Federal Express Corporation (“FedEx”) and ten Doe defendants. On August 23, 2007, the action was removed to this court. Subsequently, on May 19, 2008, Otterson amended his complaint to state the conversion claim against FedEx, two corporate entities respectively identified as Kinko’s, Inc., and Fedex Kinko’s Office and Print Services, Inc. (collectively, “Kinko’s” ), and eight Doe defendants, as well as a claim styled as a breach of bailment alleged only against Kinko’s. This court has federal question and supplemental jurisdiction over Otterson’s claims pursuant to 28 U.S.C. §§ 1331 and 1367 (as discussed in greater detail below).
In 1999, the Ninth Circuit expressly “agree[d] with the Fifth Circuit that federal common law applies to loss of or damage to goods by interstate common carriers by air,” Read-Rite Corp. v. Burlington Air Express, Ltd., 186 F.3d 1190, 1195 (9th Cir.1999), citing Deiro, 816 F.2d at 1365;also referencing Majors, 117 F.3d at 928, and further expressly “agree[d] with the Fifth Circuit that state law regulating the scope of air carrier liability for loss or damage to cargo is preempted by the [Act].” Read-Rite, 186 F.3d at 1197,citing Majors, 117 F.3d at 929 n. 15, 931;also citing Deiro, 816 F.2d at 1365. The Read-Rite court additionally affirmed that the application of state contract law to routine breach-of-contract claims was not preempted by the Act, see id.

On March 13, 2007, Otterson shipped a package to Bain’s address via FedEx, from the Kinko’s outlet at SW 2nd and Alder in Portland, OR. It may reasonably be inferred from Otterson’s sworn declaration, and defendants do not deny for purposes of the motions now before the court, that the package contained the Rolex watch that Bain had agreed to purchase. On the FedEx airbill, Otterson listed the shipper as “Kevin Otterson; KWP, Inc.; 8260 E. Raintree Drive, Suite 108; Scottsdale, Arizona,” and declared the value of the package’s contents as equal to “$0.00.”