United States v. Phillip Loyd, 886 F.3d 686

Phillip Loyd pleaded guilty to sex trafficking of a minor (18 U.S.C. § 1591(a)) and production of child pornography (18 U.S.C. § 2251(a)).
18 U.S.C. § 2251(e) imposes a mandatory minimum 25-year term for § 2251(a) offenders who have a prior conviction listed in that subsection.
Loyd had a prior federal conviction under chapter 117 (18 U.S.C. § 2422(a): inducing interstate travel for prostitution), which the district court treated as a qualifying predicate under § 2251(e).
The district court raised the advisory Guidelines bottom from 292 to 300 months to account for the statutory minimum (USSG § 5G1.1(c)(2)) and sentenced Loyd to 324 months (within the adjusted range).
Loyd appealed, arguing the phrase "relating to" in § 2251(e) limits the listed federal chapters (including chapter 117), so his chapter 117 conviction should not trigger the § 2251(e) mandatory minimum; the Eighth Circuit affirmed.

Issue	Loyd's Argument	Government's Argument	Held
Whether the qualifying-language "relating to" in 18 U.S.C. § 2251(e) limits only state laws or also the enumerated federal chapters and sections	"Relating to" modifies all prior listed federal chapters/sections, so Loyd's chapter 117 conviction does not qualify	"Relating to" modifies only the immediately preceding phrase "the laws of any State," so the listed federal chapters/sections qualify	The phrase modifies only "the laws of any State;" the chapter 117 conviction qualifies and the mandatory minimum applies

Barnhart v. Thomas, 540 U.S. 20 (construing the rule of the last antecedent)
Lockhart v. United States, 136 S. Ct. 958 (2016) (discussing last-antecedent and series-qualifier canons)
United States v. Bass, 404 U.S. 336 (1971) (series-qualifier canon and construing modifiers in lists)
Wong v. Minn. Dep't of Human Servs., 820 F.3d 922 (8th Cir. 2016) (applying series-qualifier canon and Bass discussion)
United States v. Pritchett, 470 F.2d 455 (D.C. Cir. 1972) (statutory-list parsing and textual-structure analysis)