Whether 18 U.S.C. § 1591(c) creates a strict-liability-offense-for-age-of-victim

QUESTION PRESENTED FOR REVIEW Federal sex trafficking statute, 18 U.S.C. § 1591(a), makes it illegal for anyone to sex traffic a minor knowing or with reckless disregard for the fact “that the person had not attained the age of 18 years and will be caused to engage in a commercial sex act.” Under that provision, the government must prove that the defendant either knew or had reckless disregard for the fact that the victim was a minor. Another provision in the same statute provides as follows: In the prosecution under subsection (a)(1) in which the defendant had a reasonable opportunity to observe the person so recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, or solicited, the Government need not prove that the defendant knew, or recklessly disregarded the fact, that the person had not attained the age of 18 years. 18 U.S.C. § 1591(c). This petition presents the following questions: Whether 18 U.S.C. § 1591(c) creates a self-standing strict liability offense with regard to the age of the victim that removes the mens rea element in § 1591(a) so that the government does not have to charge or prove that the defendant either knew or had a reckless disregard for the fact that the victim was a minor and which precludes a defendant from introducing any evidence that the defendant had no knowledge that the victim was minor, that the defendant did not recklessly disregard the fact that the victim was a minor and that it was reasonable for the defendant to think that the victim was not a minor? i INTERESTED PARTIES There are no