United States v. Whyte

The government may prove sex trafficking of a minor, 18 U.S.C. 1591, by establishing only that a defendant had a reasonable opportunity to observe the minor victim instead of proving that he knew or recklessly disregarded the victim's age. The Eleventh Circuit affirmed defendants' convictions for sex trafficking a minor and held that the 2015 amendment of section 1591 makes clear that the government may satisfy its burden by proving that the defendant had a reasonable opportunity to observe the minor victim. The court also held that defendants' challenges to the jury instructions, the denial of their motions to suppress evidence, the limitations on cross-examination of the victim, and their sentences all failed. View "United States v. Whyte" on Justia Law