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Anton Joseph Lazzaro v. United States

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 23-3098, 23-3411 · judgment February 25, 2025


Certiorari denied · October 6, 2025
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Does a person who engages in otherwise lawful, consensual sex with a 16 or 17-year-old dating partner commit “sex-trafficking” if the person gives unconditional gifts to the date? May a person be convicted under 18 U.S.C. § 1591(a), for the sex trafficking of a minor without knowledge that a minor would be caused to engage in a commercial sex act?

Counsel of record

For petitioner
Daniel L. Gerdts
Daniel L. Gerdts, Lawyer

For respondent
D. John Sauer
Solicitor General

Case

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, October 6, 2025 · Certiorari denied

Proceedings

  1. Oct 06 2025
    Petition DENIED.
  2. Aug 27 2025
    DISTRIBUTED for Conference of 9/29/2025.
  3. Aug 20 2025
    Waiver of right of respondent United States to respond filed.
  4. Aug 04 2025
    Petition for a writ of certiorari filed. (Response due September 8, 2025)