United States v. Tyson

947 F.3d 139 (2020)

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United States v. Tyson

United States Court of Appeals for the Third Circuit
947 F.3d 139 (2020)

  • Written by Heather Whittemore, JD

Facts

In 2017 William Tyson (defendant) traveled from Pennsylvania to New York, picked up a 17-year-old girl, and took her back to Pennsylvania. Tyson paid the girl to engage in sexual activities, which he filmed. Tyson was arrested and charged with transporting a minor to engage in prostitution and producing child pornography in violation of 18 U.S.C. § 2423(a) and 18 U.S.C. § 2251(a), respectively. Tyson attempted to defend himself by asserting that he did not know that the girl was a minor. The United States government (plaintiff) moved to exclude Tyson’s mistake-of-age evidence, arguing that a mistake of age was not a defense to § 2423(a) or § 2251(a). The district court granted the government’s motion. Tyson was found guilty and sentenced to 180 months in prison. Tyson appealed the district court’s granting of the government’s motion to exclude mistake-of-age evidence, arguing that knowledge of a minor victim’s age was an element of § 2423(a) and § 2251(a) and that mistake of age was an affirmative defense to both statutes.

Rule of Law

Issue

Holding and Reasoning (Restrepo, J.)

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