{
  "document_metadata": {
    "page_number": "56",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page56 of 113\n\nPOINT II\n\nALL COUNTS ARE BARRED BY THE STATUTE OF LIMITATIONS\n\nFor noncapital offenses such as those with which Appellant was charged, the statute of limitations is five years. 18 U.S.C. § 3282(a). It is undisputed that a 5-year limitations period would bar all charges brought against Defendant.\n\nTo escape the consequences of its delay in bringing these charges, the Government hangs its hat on 18 U.S.C. § 3283. Section 3283 is a narrow exception to the statute of limitations, but its application can expose a person to criminal prosecution during the lifetime of anyone who accuses him or her of child abuse or kidnapping. To guard against overreach, it is important to recall the well-settled “principle that criminal limitations statutes are to be liberally interpreted in favor of repose.” Toussie, 397 U.S. at 115 (quoting U.S. v. Scharton, 285 U.S. 518 (1926)). Indeed, the Government’s and District Court’s capacious reading of §3283 would have wide-ranging ramifications in this Circuit—beyond Maxwell’s case—if blessed by this Court.\n\nSection 3283 provides that “[n]o statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child, or for ten years after the offense, whichever is longer.”\n\n41\nDOJ-OGR-00021103",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page56 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "POINT II\n\nALL COUNTS ARE BARRED BY THE STATUTE OF LIMITATIONS\n\nFor noncapital offenses such as those with which Appellant was charged, the statute of limitations is five years. 18 U.S.C. § 3282(a). It is undisputed that a 5-year limitations period would bar all charges brought against Defendant.\n\nTo escape the consequences of its delay in bringing these charges, the Government hangs its hat on 18 U.S.C. § 3283. Section 3283 is a narrow exception to the statute of limitations, but its application can expose a person to criminal prosecution during the lifetime of anyone who accuses him or her of child abuse or kidnapping. To guard against overreach, it is important to recall the well-settled “principle that criminal limitations statutes are to be liberally interpreted in favor of repose.” Toussie, 397 U.S. at 115 (quoting U.S. v. Scharton, 285 U.S. 518 (1926)). Indeed, the Government’s and District Court’s capacious reading of §3283 would have wide-ranging ramifications in this Circuit—beyond Maxwell’s case—if blessed by this Court.\n\nSection 3283 provides that “[n]o statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child, or for ten years after the offense, whichever is longer.”",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "41",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021103",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Appellant",
      "Defendant",
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "District Court",
      "U.S."
    ],
    "locations": [
      "Circuit"
    ],
    "dates": [
      "02/28/2023",
      "1926"
    ],
    "reference_numbers": [
      "22-1426",
      "59",
      "3475902",
      "18 U.S.C. § 3282(a)",
      "18 U.S.C. § 3283",
      "397 U.S.",
      "285 U.S. 518",
      "DOJ-OGR-00021103"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving child abuse or kidnapping charges. The text discusses the statute of limitations and its exceptions. The document is well-formatted and printed, with no visible handwriting or stamps."
}