United States v. Chappell, 665 F.3d 1012

June 2007 hotel-room prostitution suspicions lead to Chappell's arrest with cash, condoms, IDs, and a list of names and amounts.
Buell testified Chappell recruited her as a prostitute; Buell stated she was seventeen.
A residence search found Chappell with three women, cell phones, drugs, and cash.
Chappell's indictment charged recruiting Buell to work as a prostitute when she was seventeen (18 U.S.C. § 1591).
The 2007 version of § 1591 required actual knowledge that the person was under 18; the 2008 amendments added reckless disregard language; district court instructed under amended law.
Chappell was convicted and sentenced to 336 months; he appealed challenging the jury instruction on knowledge vs reckless disregard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instruction on knowledge vs reckless disregard was plain error.	Chappell argues the instruction misstated the knowledge element for 2007 conduct.	Government contends the instruction was proper under the 2008 amendment and that any error was harmless.	Yes, plain error; reverse and remand for new trial.

Johnson v. United States, 520 U.S. 461 (1997) (plain-error standard for reversal; requires plain error affecting substantial rights)
Olano v. United States, 507 U.S. 725 (1993) (three-part test for plain error; affects fairness of proceedings)
Marcus v. United States, 130 S. Ct. 2159 (2010) (erroneous jury instruction on an element is not structural error; plain error review applies)
Yates v. Evatt, 500 U.S. 391 (1991) (structural-error concept cited in context of error type)