{
  "document_metadata": {
    "page_number": "56",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 56 of 239\nof § 3509(k) applied to conduct predating its enactment in 1990)). The Eighth Circuit's reasoning—which addressed earlier versions of the statute—applies with equal, if not greater, force to the 2003 amendment, which established an even broader statute of limitations. Following Jeffries, the Ninth Circuit has similarly held that Section 3283 applies retroactively, because “Congress evinced a clear intent to extend” the statute of limitations. Leo Sure Chief, 438 F.3d at 924 (citing Jeffries, 405 F.3d at 685).\nNot only does the wording of the statute clearly express that Congress intended for the 2003 amendment to be the only governing statute of limitations for live claims of child sexual abuse, but the legislative history also supports this conclusion. The Joint Report accompanying the 2003 amendment explains that Congress wanted to expand the statute of limitations out of concern that the 1994 amendment did not go far enough to ensure that perpetrators of child sexual abuse were held to account:\nWhile [the statute of limitations allowing for prosecution until the victim reaches age 25] is better than a flat five-year rule [under Section 3282], it remains inadequate in many cases. For example, a person who abducted and raped a child could not be prosecuted beyond this extended limit — even if DNA matching conclusively identified him as the perpetrator one day after the victim turned 25.\nH.R. Conf. Rep. No. 108-66, at 54 (2003). Congress's express intention was to prevent perpetrators of crimes against children from escaping justice based on a timing technicality. Moreover, since the 2003 amendment extended the statute of limitations throughout the lifetime of the victim, it is clear that Congress expressly authorized prosecutions to occur decades after crimes had been committed.13\n13 Although the defendant claims that prosecuting her crimes now presents unique fairness concerns, there is nothing unusual about prosecuting sex crimes long after they have occurred. See, e.g., United States v. Brown, 800 F. App'x 455, 461 (9th Cir. 2020) (2014 indictment charging, among other crimes, sex trafficking offenses dating to 2000 and 2001), cert. denied, No. 20-5064, -- S. Ct. -- , 2021 WL 78235 (Jan. 11, 2021); United States v. Pierre-Louis, No. 16 Cr. 541 (CM),\n29\nDOJ-OGR-00002990",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 56 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of § 3509(k) applied to conduct predating its enactment in 1990)). The Eighth Circuit's reasoning—which addressed earlier versions of the statute—applies with equal, if not greater, force to the 2003 amendment, which established an even broader statute of limitations. Following Jeffries, the Ninth Circuit has similarly held that Section 3283 applies retroactively, because “Congress evinced a clear intent to extend” the statute of limitations. Leo Sure Chief, 438 F.3d at 924 (citing Jeffries, 405 F.3d at 685).\nNot only does the wording of the statute clearly express that Congress intended for the 2003 amendment to be the only governing statute of limitations for live claims of child sexual abuse, but the legislative history also supports this conclusion. The Joint Report accompanying the 2003 amendment explains that Congress wanted to expand the statute of limitations out of concern that the 1994 amendment did not go far enough to ensure that perpetrators of child sexual abuse were held to account:\nWhile [the statute of limitations allowing for prosecution until the victim reaches age 25] is better than a flat five-year rule [under Section 3282], it remains inadequate in many cases. For example, a person who abducted and raped a child could not be prosecuted beyond this extended limit — even if DNA matching conclusively identified him as the perpetrator one day after the victim turned 25.\nH.R. Conf. Rep. No. 108-66, at 54 (2003). Congress's express intention was to prevent perpetrators of crimes against children from escaping justice based on a timing technicality. Moreover, since the 2003 amendment extended the statute of limitations throughout the lifetime of the victim, it is clear that Congress expressly authorized prosecutions to occur decades after crimes had been committed.13\n13 Although the defendant claims that prosecuting her crimes now presents unique fairness concerns, there is nothing unusual about prosecuting sex crimes long after they have occurred. See, e.g., United States v. Brown, 800 F. App'x 455, 461 (9th Cir. 2020) (2014 indictment charging, among other crimes, sex trafficking offenses dating to 2000 and 2001), cert. denied, No. 20-5064, -- S. Ct. -- , 2021 WL 78235 (Jan. 11, 2021); United States v. Pierre-Louis, No. 16 Cr. 541 (CM),",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "29",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002990",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Eighth Circuit",
      "Ninth Circuit",
      "Congress"
    ],
    "locations": [],
    "dates": [
      "1990",
      "2003",
      "1994",
      "2000",
      "2001",
      "2020",
      "2021",
      "Jan. 11, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "§ 3509(k)",
      "Section 3283",
      "Section 3282",
      "H.R. Conf. Rep. No. 108-66",
      "438 F.3d at 924",
      "405 F.3d at 685",
      "800 F. App'x 455, 461",
      "No. 20-5064",
      "2021 WL 78235",
      "No. 16 Cr. 541 (CM)",
      "DOJ-OGR-00002990"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a child sexual abuse case. The text discusses the statute of limitations and its application to the case. The document includes citations to various court cases and legislative history."
}