United States v. John Fortner, 943 F.3d 1007

FBI undercover agent posed as a mother on Craigslist; John Charles Fortner solicited sex with her children, sent child pornography links, and arranged an in-person meeting.
At the restaurant meeting, after confirming his intent to engage in sexual conduct with the officer’s (purported) child, Fortner was arrested.
Indicted on two counts: (1) attempt to coerce a minor into sexual activity (18 U.S.C. § 2422(b)) and (2) a 10-year sentencing enhancement for a registrant who commits an offense "involving a minor" (18 U.S.C. § 2260A).
Fortner pleaded guilty to the attempt count but moved to dismiss the § 2260A charge, arguing his conduct targeted a fictitious child and thus did not "involve a minor."
The district court denied the motion; the Sixth Circuit affirmed, holding an attempted § 2422(b) offense aimed at a purported minor qualifies as an "offense involving a minor" for § 2260A.

Issue	Plaintiff's Argument (Fortner)	Defendant's Argument (Gov't)	Held
Whether an attempt to coerce a pretend/fictitious child constitutes an "offense involving a minor" under § 2260A	Because the targeted child was not real, the underlying conviction did not "involve a minor" and § 2260A enhancement doesn't apply	§ 2260A incorporates attempt offenses; § 2422(b) criminalizes attempts aimed at minors, including undercover/purported minors; enhancement applies	Affirmed: an attempt to coerce a purported minor qualifies as an offense involving a minor for § 2260A
Vagueness / rule of lenity challenge to § 2260A application	The statute is ambiguous whether it covers attempts involving non-existent children; ambiguity triggers lenity or vagueness reversal	Statutory context and precedent make application clear; no constitutional vagueness or lenity problem	Rejected: statute is not unconstitutionally vague and lenity does not apply

United States v. Roman, 795 F.3d 511 (6th Cir. 2015) (attempt convictions under § 2422(b) can involve undercover agents posing as minors)
United States v. Wesley, 417 F.3d 612 (6th Cir. 2005) (attempt requires substantial-step analysis)
United States v. Hughes, 632 F.3d 956 (6th Cir. 2011) (attempt prosecution precedent under § 2422(b))
United States v. Slaughter, 708 F.3d 1208 (11th Cir. 2013) (holding an attempt to coerce a fictitious child counts as an offense involving a minor)
United States v. Rhodes, 253 F.3d 800 (5th Cir. 2001) (recognizing coverage of attempt crimes in child-predation context)
BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) (statutory-context canon cited)
Barber v. Thomas, 560 U.S. 474 (2010) (explaining when rule of lenity applies)
United States v. Int’l Minerals & Chem. Corp., 402 U.S. 558 (1971) (ignorance of law is no defense)