Criminal Law
Age mistakes do not erase child-exploitation convictions
The First Circuit said a defendant’s belief about a victim’s age does not matter under 18 U.S.C. § 2251(a), the federal child-sexual-exploitation statute. Rayevon Deschambault’s convictions and 216-month sentence remained in place.
The First Circuit said defendants charged with sexually exploiting a minor cannot escape liability by claiming they thought the victim was an adult. The ruling leaves Rayevon Deschambault’s convictions intact and reinforces a rule prosecutors can keep using in federal child-exploitation cases.
- A defendant’s mistaken belief about age is no defense under § 2251(a).
- The First Circuit left Rayevon Deschambault’s convictions in place.
- Officers found two videos during a warrant search of his iPhone.
- Deschambault’s 216-month sentence remains intact.
- The First Circuit has shut the door on a mistake-of-age defense in federal child-sexual-exploitation cases
The First Circuit has shut the door on a mistake-of-age defense in federal child-sexual-exploitation cases. Under 18 U.S.C. § 2251(a), it does not matter whether a defendant knew the victim was underage or believed the victim was an adult.
That ruling left Rayevon Deschambault’s two convictions in place.
The videos that brought the case to court
Deschambault’s case grew out of a drug-trafficking sting. After his arrest, police obtained a warrant to search his iPhone for evidence tied to that case, and officers found two videos showing him having sex with a minor.
The panel also rejected his challenges to suppression, voir dire and the jury instructions. But on the central issue, the judges said the statute does not turn on what the defendant thought about the victim’s age.
A rule that leaves less room to maneuver
For prosecutors, the decision keeps the focus on the conduct itself, not on a defendant’s claimed misunderstanding. For defendants, it removes one of the defenses that can sound plausible to a jury but has no traction under the statute as the First Circuit reads it.
Deschambault was sentenced to 216 months in prison, followed by ten years of supervised release. The ruling leaves that punishment untouched.