United States v. Copeland, No. 15-50208 (5th Cir. 2016)
Annotate this CaseDefendant was convicted of sex trafficking of children in violation of 18 U.S.C. 1591. The court joined the Second Circuit in concluding that, under the version of section 1591(c) applicable to defendant, the Government “need not prove any mens rea with regard to the defendant’s awareness of the victim’s age if the defendant had a reasonable opportunity to observe the victim.” Given that Congress can - and often does - reduce or eliminate scienter requiring knowledge of a minor victim’s age in sex crimes, the court held that defendant's conviction under section 1591(c) did not violate his due process rights. Accordingly, the court affirmed the judgment.
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