The Seventh Circuit has determined that an Indiana child molesting conviction categorically relates to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor for purposes of a federal child pornography sentencing enhancement. The defendant argued that the Indiana statute was overbroad because it did not include the same offender-age or age-difference requirements found in federal definitions.
The Court rejected that argument, relying on its broad interpretation of the phrase “relating to” in the enhancement statute. The Court found that the Indiana offense targets the same general harm: sexual exploitation of young children. Although this is a criminal sentencing case, the categorical approach discussion may be useful in immigration cases involving sex-offense predicates.
The full text of United States v. Schatz can be found here: https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D06-09/C:24-2252:J:Kolar:aut:T:fnOp:N:3555194:S:0