Whether a state offense relates to the 'sexual exploitation of children' under 18 U.S.C. § 2251(e)

QUESTION PRESENTED Congress criminalized the “sexual exploitation of children” in 18 U.S.C. § 2251. Subsections (a) through (d) of that statute articulate the federal offenses—each of which involves the production or distribution of child pornography. Subsection (e) provides the sentencing ranges for the federal offenses. A higher range, with a 35-year minimum, applies when a defendant has two or more prior state convictions “relating to the sexual exploitation of children.” The question presented is: Whether, for purposes of 18 U.S.C. § 2251(e), a state offense relates to the “sexual exploitation of children” only when it relates to child pornography, as the Ninth Circuit holds; when it relates to child pornography or child abuse, as the Sixth Circuit holds; or when it relates to any criminal sexual activity involving children, as the First, Third, Fourth, Fifth, and Eighth Circuits hold?