What is the proper definition of 'relating to the sexual exploitation of children' in 18 U.S.C. §2251(e)?

QUESTION PRESENTED The federal criminal statute entitled Sexual Exploitation of Children provides a series of mandatory-minimum penalties. 18 U.S.C. §2251(e). The penalty for violating §2251(a) is generally 15-30 years of incarceration. Jd. Someone with one prior conviction under enumerated federal laws or a state law “relating to aggravated sexual abuse, sexual abuse, abusive sexual contact involving a minor or ward, or sex trafficking of children, or the production, possession, receipt, mailing, sale, distribution, shipment, or transportation of child pornography,” is subject to 25-50 years of incarceration (the 25-year minimum). Jd. Someone with two or more convictions under certain federal laws or a state law “relating to the sexual exploitation of children,” is subject to 35 years to life (the 35-year minimum). Jd. The question presented is the proper definition of “relating to the sexual exploitation of children” in 18 U.S.C. §2251(e). It is an important question that impacts many individuals each year. U.S. Sent’g Comm’n, Mandatory Minimum Penalties for Sex Offenses in the Federal Criminal Justice System, at 19 (2019), available at There is a Circuit split on this issue, which implicates this Court’s statutory interpretation and rule of lenity jurisprudence. This Court should resolve this important question. i