United States v. Datqunn Sawyer
2013 U.S. App. LEXIS 21567
| 7th Cir. | 2013Background
- Sawyer was convicted of sex trafficking of minors under 18 U.S.C. § 1591(a) and sentenced to 50 years.
- Sawyer admitted he forced at least seven underage girls to work as prostitutes for his benefit.
- He contends the jury instructions misstated the mens rea requirement by not requiring knowledge of interstate commerce.
- The court found the claim waived because Sawyer’s attorney stated no objection to the instructions at trial.
- Even if preserved, the court held the interstate-commerce element in § 1591(a) does not require knowledge or intent, so the instruction was correct.
- The conviction was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 1591(a) require knowledge for the interstate commerce element? | Sawyer argues knowledge/intent is required. | Sawyer contends the government must prove he knew interstate effects. | No knowledge requirement for interstate element; statute allows strict liability as to commerce. |
| Was Sawyer's challenge waived by failure to object to instructions? | Sawyer’s waiver; attorney said no objections. | Government correctly invoked waiver. | Waiver existed; challenge deemed waived. |
| If preserved, are the instructions correct on the merits? | Even with preservation, the knowledge requirement would negate guilt. | Interstate-commerce element does not require knowledge. | Merits support no knowledge requirement; instruction correct. |
| Should this case depart from established caselaw on mens rea for commerce elements? | Sawyer urges departure to require knowledge. | Court adheres to broad rule that interstate element need not be known. | Court follows prevailing caselaw; keeps no mens rea for commerce element. |
Key Cases Cited
- United States v. Kirklin, 727 F.3d 711 (7th Cir. 2013) (waiver of objections to jury instructions at trial)
- United States v. Griffin, 493 F.3d 856 (7th Cir. 2007) (waiver and forfeiture principles in trial)
- United States v. Feola, 420 U.S. 671 (Supreme Court 1975) (jurisdictional hooks do not require actor's knowledge of federal nexus)
- United States v. Soy, 454 F.3d 766 (7th Cir. 2006) (interstate-commerce element often has no mens rea requirement)
- United States v. Lindemann, 85 F.3d 1232 (7th Cir. 1996) (no mens rea for interstate commerce element in wire/related statutes)
- United States v. Hattaway, 740 F.2d 1419 (7th Cir. 1984) (Mann Act context—knowledge not required for interstate element)
- United States v. Driggers, 559 F.3d 1021 (9th Cir. 2009) (murder-for-hire; considerations of mens rea for nexus elements)
- United States v. Darby, 37 F.3d 1059 (4th Cir. 1994) (threatening communication; nexus element considerations)
- United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) (interstate commerce element on § 1591(a))