United States v. Douglas, 626 F.3d 161

Undercover detective Chaulk joined a fetish chat room posing as a 38-year-old, claiming to be a mother of a 13-year-old daughter.
Douglas appeared in the chat as an older man, stating training of young girls and offering to transport a minor to Alabama for sexual activity.
Douglas engaged in explicit discussions about sexual activities with the apparent minor and offered payment for travel and sexual acts.
Detective Chaulk showed Douglas an image of a purported 13-year-old girl and a separate image of himself to demonstrate realism and seriousness.
A Vermont district court later charged Douglas with one count of enticing a minor to engage in illegal sexual activity in violation of 18 U.S.C. § 2422(b) and one count of transporting child pornography in interstate commerce under 18 U.S.C. § 2252A(a)(1).
Douglas was convicted by a jury on both counts and appealed challenging whether communications with an adult guardian could satisfy § 2422(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2422(b) requires targeting a minor directly.	Douglas argues communications must be to a minor.	Douglas contends no conviction where guardian is the intermediary.	No; intermediary communications can satisfy § 2422(b).

United States v. Brand, 467 F.3d 179 (2006) (statutory scope includes obtaining a minor's assent via guardian)
United States v. Nestor, 574 F.3d 159 (2009) (guardian intermediary can support enticement)
United States v. Spurlock, 495 F.3d 1011 (2007) (intermediary approach upheld)
United States v. Murrell, 368 F.3d 1283 (2004) (protects against evading § 2422(b) through intermediaries)
United States v. Bailey, 228 F.3d 637 (2000) (intent to persuade or attempt to persuade suffices)