United States Second Circuit

In appeal from conviction on two counts of sex trafficking of a minor, judgment is affirmed, where: 1) the court concludes, in a matter of first impression, that an evidentiary provision added by the Trafficking Victims Protection Reauthorization Act of 2008 imposes strict liability with regard to the defendant’s awareness of the victim's age, thus relieving the government's usual burden to prove knowledge or reckless disregard of the victim's underage status under 18 U.S.C section 1591(a); and 2) defendant's remaining evidentiary and sentencing challenges lack merit.

Appellate Information

• Decided 11/30/2012
• Published 11/30/2012

Judges

• CABRANES

Court

• United States Second Circuit

Counsel