United States v. Charles E. Jones, Iii, A/K/A Chuckie
2006 U.S. App. LEXIS 31514, 471 F.3d 535, 2006 WL 3759378 (2006)
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Rule of Law:
A conviction under 18 U.S.C. § 2423(a) for transporting a minor across state lines for prostitution does not require the government to prove that the defendant knew the victim was under 18 years of age. The victim's minor status is a strict liability element of the offense.
Facts:
- In September 2003, Charles E. Jones III and his associate, Jamie Derek Bennett, met a thirteen-year-old runaway in Bellaire, Ohio.
- For three consecutive nights, Jones and Bennett transported the girl from Ohio to the Dallas Pike Truck Stop in West Virginia.
- The purpose of these trips was for the girl to perform sex acts on truckers for money.
- Jones and Bennett provided the girl with makeup, skimpy clothing, condoms, douches, and a fake ID.
- They also developed a pricing scale for the various sex acts she was to perform.
- During the acts, Jones and Bennett waited in their car, and the girl would periodically return to give them the money she earned.
- Jones and Bennett used the proceeds from the prostitution to purchase alcohol and illegal drugs.
- On the third night, after a dangerous encounter with a customer, the girl decided she would no longer engage in prostitution.
Procedural Posture:
- Charles E. Jones III was indicted by a federal grand jury in the United States District Court for the Northern District of West Virginia.
- Before the jury, the government presented evidence and argued that knowledge of the victim's age was not an element of the crime.
- A jury convicted Jones on one count of conspiracy and three counts of aiding and abetting the transportation of a minor across state lines for sexual purposes.
- The district court sentenced Jones to 63 months of imprisonment.
- Jones (appellant) appealed his conviction to the United States Court of Appeals for the Fourth Circuit.
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Issue:
Does a conviction under 18 U.S.C. § 2423(a), which prohibits knowingly transporting a minor across state lines for prostitution, require the government to prove that the defendant had knowledge of the victim's minor status?
Opinions:
Majority - Wilkinson
No. A conviction under 18 U.S.C. § 2423(a) does not require proof that the defendant knew the victim was a minor. The plain grammatical structure of the statute indicates the adverb 'knowingly' modifies the verb 'transports,' not the subsequent clause describing the victim's age. The court reasoned that Congress intended to provide heightened protection for minors, and requiring proof of knowledge would subvert this purpose by allowing defendants to feign ignorance of a victim's age. Unlike cases involving otherwise innocent conduct (e.g., possessing what appears to be a legal firearm), the underlying act of transporting any individual for prostitution is already illegal under 18 U.S.C. § 2421. Therefore, the victim's age serves as a factor that subjects the defendant to a more severe penalty, and the defendant assumes the risk that the person they are exploiting is a minor.
Analysis:
This decision solidifies the interpretation of 18 U.S.C. § 2423(a) as a strict liability offense concerning the victim's age, aligning the Fourth Circuit with the Second, Third, Ninth, and Tenth Circuits. By removing the need for prosecutors to prove a defendant's knowledge of the victim's minority, the ruling significantly lowers the evidentiary burden in such cases. This reinforces the statute's protective purpose and prevents defendants from using ignorance—whether real or feigned—as a defense, thereby strengthening legal protections against the sexual exploitation of minors.
