United States v. Henry, No. 15-1523 (1st Cir. 2016)
Annotate this CaseDefendant entered a conditional guilty plea to two counts of sexual exploitation of children. Defendant appealed, arguing that the district court erred in determining that he was not entitled to raise a “mistake of age” defense and in denying his motion to suppress evidence found in connection with a search of his motel room. The First Circuit affirmed, holding (1) 18 U.S.C. 2251(a) plainly does not require that a person convicted of violating the statute needs to know the actual age of the minor victim, the limited scienter requirements of section 2251(a) do not violate the over breadth doctrine, and the mandatory minimum sentence of fifteen years for violation of the statute is not grossly disproportionate; and (2) the district court did not err in denying Defendant’s motion to suppress.
The court issued a subsequent related opinion or order on June 29, 2016.
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