United States v. Robinson, No. 11-301 (2d Cir. 2012)Annotate this Case
Defendant appealed from his conviction of two counts of sex trafficking of a minor. At issue was the appropriate construction of 18 U.S.C. 1591(c), an evidentiary provision added by the William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), Pub. L. No. 110-457, 122 Stat. 5044. The court held that this provision, when applicable, imposed strict liability with regard to 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 section 1591(a). The court rejected defendant's remaining evidentiary and sentencing challenges as lacking merit and therefore affirmed the judgment of the district court.