United States v. Winczuk, 67 F.4th 11

Defendant-appellant Jordan Winczuk pleaded guilty to attempted sexual exploitation of a minor (18 U.S.C. § 2251) and committing a felony involving a minor while required to register as a sex offender (18 U.S.C. § 2260A).
At sentencing the district court imposed a total of 45 years’ imprisonment: a 35-year mandatory minimum under § 2251(e) (based on two prior state convictions) consecutive to a 10-year mandatory minimum under § 2260A.
Winczuk has two prior New Jersey convictions: (1) sexual assault of a minor (plea in 2010) and (2) endangering the welfare of a child by file sharing child pornography (plea in 2010); both required sex-offender registration.
On appeal Winczuk argued the statutory phrase "relating to the sexual exploitation of children" in § 2251(e) should be read to refer only to production of child pornography, so his prior convictions do not trigger the 35-year recidivist minimum.
The First Circuit rejected that narrow reading, adopting a broad construction that the phrase covers any criminal sexual conduct involving children, and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the phrase "relating to the sexual exploitation of children" in 18 U.S.C. § 2251(e) is limited to production of child pornography	Winczuk: phrase should be read narrowly to mean only offenses involving production of child pornography	Government: phrase covers any conduct that takes sexual advantage of a child (broad reading)	The court held the phrase unambiguously covers any criminal sexual conduct involving children, not just child-pornography production; 35-year minimum applies

United States v. Pavulak, 700 F.3d 651 (3d Cir. 2012) (adopts broad reading of "sexual exploitation of children")
United States v. Mills, 850 F.3d 693 (4th Cir. 2017) (interprets phrase to include child sexual abuse and exploitation beyond production)
United States v. Randolph, 364 F.3d 118 (3d Cir. 2004) (rejects production-only reading; includes child molestation)
United States v. Smith, 367 F.3d 748 (8th Cir. 2004) (concludes phrase refers to criminal sexual conduct with a child)
Esquivel-Quintana v. Sessions, 581 U.S. 385 (2017) (statutory-interpretation principles for phrase meanings)
Ocasio v. United States, 578 U.S. 282 (2016) (explains narrow application of the rule of lenity)
Tanzin v. Tanvir, 141 S. Ct. 486 (2020) (directs interpretation according to plain meaning at enactment)
United States v. Blodgett, 872 F.3d 66 (1st Cir. 2017) (standard of review: de novo for statutory interpretation)