Professor Carissa Hessick of the University of Utah discusses the application of the rules of statutory construction to the case Lockhart v. U.S., in which Lockhart pled guilty to receipt of child pornography. The trial court enhanced Lockhart’s sentence because of his prior conviction for the sexual assault of an adult woman. Lockhart objects to the sentencing enhancement, alleging that only prior convictions for crimes involving minors qualify under the relevant statute. In contrast, the government argues that all prior sex offenses constitute prior convictions for purposes of sentencing enhancement.
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