Zackary Ellis Sanders v. United States

18 U.S.C. § 2251(a) provides that “Any person who employs, uses, persuades, induces, entices, or coerces any minor to engage in . . . any sexually explicit conduct for the purpose of producing any visual depiction of such conduct . . . shall be punished as provided under [this section].” The questions presented are:

1. In accordance with the method of statutory interpretation set forth in Dubin v. United States, 599 U.S. 110 (2023), should the term “uses” be interpreted in the context of the statute and the other actus reus verbs listed in it.

2. Whether “for the purpose of” should be interpretated in accordance with the plain language of the statute to mean the purpose, rather than merely “a” purpose even if not the primary purpose.